VQ COMMUNICATIONS – WEBSITE PRIVACY POLICY

This privacy policy explains how personal data is collected and used when you use our website. It also explains how we process any data that you supply to us on this website, for instance, to request access to our Customer Portal or request a product demo.

VQ Communications Ltd of Unit 4b, Byron House, Landsdowne Court, Bumpers Way, Chippenham, SN14 6RZ is the Data Controller for any personal data that you supply to us through your use of the website (including as part of the software license) and support we provide to you.

Our Data Protection Officer is Giles Adams who can be contacted at info@vqcomms.com. Tel: 01249 880140.

What personal data we collect

The personal data collected depends on how you use our website. You can browse the site, you can fill in forms on the website to (amongst others) request access to our Customer Portal receive a Product Demo, register for Webinars etc., download a software license and product and marketing documents from us, or you can subscribe to our emails, and other activities. VQ Communications Ltd’s website collects personal data to provide these services.

We collect information about you when you visit our website, register for access to our Customer Portal, request a Product Demo, register for Webinars and other marketing and training events and materials and engage in business with us.

What we do with your personal data

When you visit our website, a record of your visit is made. This data includes your device’s IP address. That data is used completely anonymously, in order to determine the number of people who visit our website and the most frequently used sections of the site. This enables us to continually update and refine the site. If you use any forms on the website to send an email to us, a record will also be made of your name, email address and your telephone number.

The following table sets out how we handle your personal data and our legal basis for doing so under GDPR and the Data Protection Act 2018.

What we do Our legal basis under GDPR
Use the personal data that you provide on our web forms Performance of the contract (Article 6(1)(b)) – when you provide us with your personal data, for instance to obtain a quote for our services, this is a necessary step to take at the request of the data subject prior to entering into a contract
Provide our customers with software licenses, upgrades, technical information and product information and contact you about those services Performance of the contract (Article 6(1)(b)) – this is necessary for the performance of a contract with you, our data subject
Contact you with details of the latest versions and upgrades to our product available for purchase that we think may be of interest to you Consent (Article 6(1)(a)) – we may contact about the latest versions and upgrades to our product available for purchase where you have indicated your consent for us to contact you in this way
Retain your data under our data retention policy after your contract has expired Legitimate interests (Article 6(1)(f)) – we need to retain your personal data for only as long as necessary under the law to protect our legitimate interests
Access your log files (if you use our portal on our website) in order to resolve a problem you have reported and to, as a result, generally improve our product should the problem be one that is effecting other users Performance of the contract (Article 6(1)(b)) and our legitimate interests (Article 6(1)(f))

The following table sets out the categories of personal data that we obtain.

Personal Data Explanation
Name, postal address, email address, website, identification number, location data, online identifier – these are classed as personal data This data is provided by you on our web forms either to provide you with access to our Customer Portal, register for a Product Demonstration or Webinar and receive Product and Training material. or as part of the provision of your existing contractual services.

We may collect, hold, use and disclose the information collected to compile statistical data and to; maintain our database; develop/improve our website; respond to any email enquiries; notify you of any upcoming marketing, training or other events that you have opted in to; provide you with publications; manage quality control; manage systems administration; attend to compliance issues.

We will not use or disclose your personal information for any other purpose which is not related to the above purposes without your consent unless otherwise authorised, required or permitted under the laws of England and Wales. VQ Communications Ltd does not sell your data to third parties.

If you no longer wish to receive information about our services, please send an email to our Data Protection and Compliance Officer (info@vqcomms.com) advising that you do not wish to receive further information.

Will we disclose your data?

Personal data will only be disclosed on a confidential basis to external service providers (“data processors”) so that they can provide services such as financial or administrative services in connection with the operation or sale of our business; and to any person (where necessary) in connection with their services, such as law enforcement, regulatory authorities, partners or advisors.

For example, log files submitted to the VQ customer portal is actively managed and kept up to date from a security and patch level by VQ. However, the ticketing system used by VQ is Freshdesk (https://freshdesk.com/). Please see the following Freshdesk policies:

We do not allow our data processors 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. The processing of your personal data is governed by a data processing contract between us and our data processors, ensuring a commitment to the principals of the GDPR and the Data Protection Act 2018.

Other than this, your data is not shared with third parties without your consent, unless this is required to comply with a legal obligation placed upon us. All employees within VQ Communications that handle your personal data are trained in ensuring data is processed in line with GDPR.

Transfers outside the EEA

We may need to transfer your personal data outside the European Economic Area in the course of using some of our service providers, for example Freshdesk (see above) which is based in the US. We also use a CRM system provided by Infusionsoft (https://keap.com/legal/data-protection-faq) which is hosted in the US.

The European Commission has recognised that US companies who have registered under the Privacy Shield framework as providing adequate protection in respect of data protection. We have also entered into adequate contractual provisions with such service providers.

How long we keep your personal data

Personal data from our data subjects is retained in line with our data retention policy. VQ Communications Ltd keeps most data for 7 years, which covers the 6 years by law in which we have to keep certain information for a minimum of 6 years plus the current year. Personal data that is no longer necessary to be kept under our data retention policy will be deleted.

Your Rights

You have the following rights in relation to the personal data we hold on you:

  1. the right to be informed about the personal data we hold on you and what we do with it;
  2. the right to obtain a copy of the personal data we process concerning you. We will take steps to verify your identity before responding to your request. Once we have verified your identity we will respond as soon as possible and in any event within one month. For further information, see “Subject Access Requests” in our GPDR Compliance Statement: https://www.vqcomms.com/gdpr-compliance-statement/;
  3. the right for any inaccuracies in the personal data we hold on you, however they come to light, to be corrected. This is also known as ‘rectification’;
  4. the right to have your personal data deleted in certain circumstances. This is also known as ‘erasure’. For further information, see “Right To Be Forgotten” in our GPDR Compliance Statement: https://www.vqcomms.com/gdpr-compliance-statement/;
  5. the right to restrict or object to the processing of your personal data;
  6. the right to transfer the personal data we hold on you to another party. This is also known as ‘portability’;
  7. the right to regulate any automated decision-making and profiling of personal data.

If you wish to learn more about these rights and how they operate, please look at the ICO’s website  https://ico.org.uk/for-the-public/.

VQ Communications Ltd does not operate any automated decision-making systems.

If you are unhappy with the response that you receive from us when you exercise your GDPR rights or Data Protection Act 2018 rights, you have the right to lodge a complaint to the ICO. More guidance about raising a complaint with us is available on the ICO’s website https://ico.org.uk/for- the-public/raising-concerns/ and for raising a complaint with the ICO, more information is available on https://ico.org.uk/concerns/.

Cookies

This website uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of this website and compile reports for us on activity on the website. Google stores the information collected by the cookie on servers in the United States and the transfer of the data to servers in the USA is governed by the EU-US Privacy Shield framework. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. More information about Google’s compliance with GDPR can be obtained from their website https://privacy.google.com/businesses/compliance.

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. For further information visit www.aboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result (see ‘functionality’ cookies in the table below).

Third-party cookies

We work with third party suppliers who may also set cookies on our website, for example Google and Linkedin. These third party suppliers are responsible for the cookies they set on our site. If you want further information please go to the website for the relevant third party. You will find additional information in the table below.

Cookies generally fall into the following categories:

Session cookies are automatically deleted at the end of each browsing session, typically when the web browser is closed.

Persistent cookies remain until the expiry date and time set by the web server. They can be manually deleted by the user.

1st party cookies originate from the same domain as the website being visited.

3rd party cookies originate from a domain that is different to the website being visited. The table below provides more information about the cookies we use and why:

Name Domain Type Category Description
BizoID .ads.linkedin. com 3rd party  Marketing Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor’s preferences.
NID .google.com 3rd party Marketing Registers a unique ID that identifies a returning user’s device. The ID is used for targeted ads.
PHPSESSID www.vqcom ms.com Session Necessary Preserves user session state across page requests.
UserMatchHistory .linkedin.com 3rd party Marketing Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor’s preferences.
WLM_TEST_COOKIE www.vqcom ms.com Session Necessary Used by WishList Member. Tests whether or not the browser has cookies enabled
_ga .vqcomms.co m 3rd party Marketing Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
_gat_UA-xxxx .vqcomms.co m 3rd party Marketing Used by Google Analytics to throttle request rate
_gid .vqcomms.co m 3rd party Marketing Registers a unique ID that is used to generate statistical data on how the visitor uses the website.
bcookie .linkedin.com 3rd party Marketing Used by the social networking service, LinkedIn, for tracking the use of embedded services.
lang .ads.linkedin. com 3rd party Marketing Remembers the user’s selected language version of a website
lang .linkedin.com 3rd party Marketing Set by LinkedIn when a web page contains an embedded “Follow us” panel.
lidc .linkedin.com 3rd party Marketing Used by the social networking service, LinkedIn, for tracking the use of embedded services.
time www.vqcom ms.com Session Functionality Sets a timestamp for when the visitor entered the website. This is used for analytical purposes on the website.
wlm_user_sequential www.vqcom ms.com persistent Functionality Used by WishList Member.
wordpress_logged_in www.vqcom ms.com Session Functionality The cookie indicates when the user has logged on (WordPress).
wordpress_sec www.vqcom ms.com Session Functionality The cookie indicates when the user has logged on (WordPress).
wordpress_test_cookie www.vqcom ms.com Session Necessary Used by WordPress. Tests whether or not the browser has cookies enabled
bscookie .linkedin.com 3rd party Marketing Used by the social networking service, LinkedIn, for tracking the use of embedded services.

You can choose to reject or block all or specific types of cookies set by virtue of your visit to our website. You can change your preferences for our website and/or the websites of any third party suppliers by changing your browser settings. Please note that most browsers automatically accept cookies. Therefore, if you do not wish cookies to be used, you may need to actively delete or block the cookies.

If you reject the use of cookies, you will still be able to visit our websites but some of the functions may not work correctly. You may also visit www.allaboutcookies.org and https://ico.org.uk/for-the- public/online/cookies/ for details on how to delete or reject cookies and for further information on cookies generally.

Other websites

Our website may contain links to other sites. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policy.

How to contact us

Please review the website regularly as this statement may change from time to time. If you continue to access or use our website, you will have agreed to the revised policy.

If you have any questions about our privacy policy or information we hold about you please contact our Data Protection and Compliance Officer:

Giles Adams

Telephone 01249 880140

Email info@vqcomms.com