Privacy Policy

1. IMPORTANT INFORMATION AND WHO WE ARE

The Vision33 Group is comprised of the following operating entities:

• Vision33 Limited, registered in England and Wales (#03786914)
• Vision33 Inc., a Delaware corporation (#3740604)
• Vision33 Canada Inc., a Newfoundland and Labrador corporation (#87062)

This policy is issued on behalf of the Vision33 operating entities so when we mention Vision33, “we”, “us” or “our” in this policy, we are referring to the relevant operating entity responsible for processing your data. Vision33 Limited is the controller and responsible for this website.

We have appointed a data protection manager who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact us via the contact details provided below.

Our websites, social media pages, and services are not intended for children and we do not knowingly collect data relating to children.

2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that person can be identified – you may know this as personal information or personally identifiable information depending on where you are in the world. It does not include anonymised data, where the identity has been removed, and the identity cannot be reidentified.

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

• Contact Data includes name, role, billing address, delivery address, email address, and telephone numbers.
• Third Party Contact Data includes Contact Data for any other individual that you may provide to us, for example if there are others in your organisation that you would like us to send information about our services.
• Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Communications Data includes personal data that is included in your communications with us.
• Website Usage Data includes information about how you interact with and use our websites.
• Technical Data includes 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, device ID, and other technology on the devices you use to access this website.
• Social Media Data includes marketing data, communications data via the relevant social media channel, and limited identity data where you engage with our social media accounts.
• Profile Data includes your interests, industry preferences, feedback, and survey responses.

We also collect, use, and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Website Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3.  HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email, our social media pages, or otherwise. This includes personal data you provide when you:
  
  • Contact us about products or services your organisation may be interested in;
  • Subscribe to our publications, newsletters, and product information;
  • Request marketing to be sent to you;
  • Attend a webinar or conference;
  • Interact with us via our social media pages;
  • Complete a survey;
  • Attend our offices; or
  • Give us feedback or contact us.
• Automated technologies or interactions. As you interact with our websites, we will automatically collect Website Usage Data and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy here for further details.
• Third parties or publicly available sources. We will receive Contact Data about you from various third parties and public sources as set out below:
  • Your colleagues at your organisation, who may ask us to contact you;
  • lead generation networks who provide us with business contact details for representatives of organisations that may be interested in our services. We make every effort to ensure that your personal contact details from outside your organisation are not used when marketing our services; and
  • publicly available sources.
• Website Usage Data and Technical Data is collected from the following parties:
  • analytics providers; and
  • marketing networks.
• Social media widgets and our social media pages, which will allow you and others to interact with us, and share content via social media platforms. If you do this, then your communications and content (which may include your personal data) will be made available via those platforms, and will be subject to the platforms’ own terms and privacy policies. Those platforms may provide us with information about you, such as where you send us a message, or like or comment on us or our content. If you wish to contact us via a social media platform, you should use direct messaging rather than public messaging if you wish to share any personal data with us. Any personal data shared in public on social platforms is shared at your own risk.
• If you or your business provide information to us about another person or business you must make sure you have the right and permission to do so (e.g. by providing appropriate data collection notices to individuals who are the subject of that data). We are reliant on this in order to receive and process the information you provide.

4.  HOW WE USE YOUR PERSONAL DATA

Legal basis  

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to enable us to send your organisation marketing material, respond to your requests for information, give you a secure customer experience on our websites, and address your online job application. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter, respond to a survey, etc.
• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis
Operating our Websites and Social Media:
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data)	(a) Website Usage (b) Technical	Necessary for our legitimate interests (for running our business, responding to your support queries about our website, provision of our own administration and IT services, network security, to prevent fraud, and in the context of a business reorganisation or group restructuring exercise).
To use data analytics to improve our website, products/services, customer relationships and experiences, and to measure the effectiveness of our communications and marketing	(a) Technical (b) Website Usage (c) Marketing	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy).
To communicate with you if you choose to interact with our social media pages, and to collect social media data to analyse our potential customer relationships and customer types	(a)    Social Media	Necessary for our legitimate interests (to deal with your communications and interactions with us via our social media pages, to define types of customers for our products and services, to keep our social media pages updated and relevant, to develop our business, and to inform our marketing strategy).
Dealing with your queries and requests:
To manage our relationship with you which will include: (a) Dealing with your requests, complaints, and queries if you are dealing with us as a representative of a prospective customer	(a) Contact (b) Marketing (c) Communications	Necessary for our legitimate interests (to keep our records updated and manage our relationship with you).
Marketing and promotion:
To send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	(a) Contact (b) Profile (c) Marketing (d) Communications	(a)    Necessary for our legitimate interests (to carry out direct marketing, develop our products/services, and grow our business).   (b)    Consent, having obtained your prior consent to receiving direct marketing communications.
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Contact (b) Profile (c) Website Usage (d) Marketing (e) Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy).
To enable you to complete a survey	(a) Contact (b) Website Usage (c) Marketing (d) Communications	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and grow our business).
To carry out market research through your voluntary participation in surveys	(a) Contact (b) Marketing (c) Communications	Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).
Dealing with employment candidates:
To manage our relationship with employment candidates who use our website to apply for a job with us and to submit all associated information and documents	(a) Contact (b) Communications	(a)    Necessary for our legitimate interests (to make a decision about your recruitment or engagement, to conduct pre-engagement checks including but not limited to contacting references and confirming if you are legally entitled to work in the UK or the EU, and to assess your qualifications for a particular role).   (b)    Consent, having obtained your prior consent to use your personal data for the purpose of our applicant selection process.

 

DIRECT MARKETING  

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

Where you are a representative of an organisation, we may receive your Contact Data from your colleagues, or lead generation providers. We make every effort to ensure that such data has been collected appropriately, and will only ever send you information that we believe is relevant to you. You can opt-out of receiving such marketing messages at any time – see below.

We may also analyse your Contact, Technical, Website Usage, and Profile Data to form a view which products, services, and offers may be of interest to you so that we can then send you relevant marketing communications.

THIRD-PARTY MARKETING  

We do not provide your personal data to any third parties for their own direct marketing purposes.

OPTING OUT OF MARKETING  

You can ask us to stop sending you marketing communications at any time by opting-out at the time you provide your details to us, or by following the opt-out links within any marketing communication sent to you, or by contacting us using the details below.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to your organisation’s contract with us.

COOKIES  

For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy here.

5.  DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data where necessary with the parties set out below for the purposes set out in the table above.

• Other Vision33 operating entities where this is necessary to fulfil your request.
• Hubspot.
• SAP, Sage, and other software publishers with whom we have contractual relationships to resell their products and services to our customers.
• Top Echelon Software, LLC in respect of their CATS applicant tracking solution.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this policy.

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.

6.  INTERNATIONAL TRANSFERS

We share your personal data with other Vision33 operating entities for the purposes of fulfilling your requests and sending you relevant information about our products and services.

Whenever we transfer your personal data to countries which have laws that do not provide the same level of data protection as the country in which you are based, we always ensure that a similar degree of protection is afforded to it.

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data to countries which have laws that do not provide the same level of data protection as the country in which you are based.

Whenever we transfer your personal data to service providers, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are in place, including appropriate international data transfer mechanisms.

7.  DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8.  DATA RETENTION

How long will you use my personal data for?  

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

9.  YOUR LEGAL RIGHTS

You have a number of rights under data protection laws in relation to your personal data.

If you are based within the United Kingdom, the European Economic Area, or within another jurisdiction having similar data protection laws, you have the right to:

• Request access to your personal data (commonly known as a “data subject access request” or “DSAR”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able 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.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal data which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in Paragraph 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in Paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in any of the following scenarios:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where 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 it.

If you wish to exercise any of the rights set out above, please contact us using the contact details below.

No fee usually required  

You will not have to pay a fee to access your personal data (or to exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you  

We may need to request specific information from you to help us 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 to ensure that personal data is not disclosed to any person who 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.

Time limit to respond  

We try to respond to all legitimate requests as soon as practical. This will typically be within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.  CONTACT DETAILS

If you have any questions about this policy or about the use of your personal data or you want to exercise your privacy rights, please contact us via email to: privacy@vision33.com

11.  COMPLAINTS  

If you are based within the United Kingdom, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). If you are based within the European Economic Area, you have the right to make a complaint at any time to your national Data Protection Authority (DPA). We would, however, appreciate the chance to deal with your concerns before you approach the ICO or your DPA so please contact us in the first instance.

12.  CHANGES TO PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES  

We keep our privacy policy under regular review. This version was last updated on 1 June 2024. Historic versions can be obtained by contacting us.

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, for example a new address or email address.

13.  THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins, and applications. 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. When you leave our website, we encourage you to read the privacy policy of every website you visit.