Privacy Policy
Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use, and are responsible for certain personal information about you. When we do so, we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.
Key Terms
It would be helpful to start by explaining some key terms used in this policy:
Personal Information We Collect About You
- Your name and contact information, including your address, email address, telephone number, account information (e.g., log-in credentials), and other similar identifiers; and
- Your billing information, transaction and payment card information.
- Information to enable us to check and verify your identity, e.g., your date of birth;
- Your gender information, if you choose to give this to us;
- Your contact history, purchase history, and saved items;
- Information to enable us to undertake credit or other financial checks on you;
- Information about how you use our website, IT, communication and other systems;
- Your responses to surveys, competitions, and promotions;
Some of this personal information (e.g., name and email address) is required to provide services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you.
Further, because our website offers user-submitted posts and comments, please be advised that information posted by you via these public areas becomes public knowledge.
How Your Personal Information is Collected
We collect most of this personal information directly from you via our website and apps. However, we may also collect information:
- From publicly accessible sources;
- From a third party, but only with your consent;
- From cookies on our website; and
- Via our IT systems, e.g., monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems.
How and Why We Use Your Personal Information
Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests (or those of a third party); or
- Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
Importantly, this does not apply to special category personal information, which we will only process with your explicit consent.
Communications
Registered users may receive additional announcements from us about site news, events, private messages, uploaded photos, blog posts, and website updates. Out of respect for the privacy of our registered users, we present the option to not receive these types of communications.
Further, we will always treat your personal information with the utmost respect and never sell or share it with other organizations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us
- using the ‘unsubscribe’ link in emails
- updating your communication preferences with us
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
Who We Share Your Personal Information With
When necessary, we will share personal information with:
- Third parties we use to help deliver our services to you, e.g., payment service providers.
- Other third parties we use to help us run our business, e.g., accountants, attorneys, auditors, or website hosts;
- Third parties approved by you, e.g., social media sites you choose to link your account to or third party payment providers;
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymized, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
We Do Not Sell or Disclose Personal Information.
We do not sell any personal information about you to any third parties for any purpose.
Where Your Personal Information is Held
Information may be held at our offices and those of our service providers, representatives, and agents as described above (see above: “Who We Share Your Personal Information With”).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.
How Long Your Personal Information Will Be Kept
We will keep your personal information while you have an account with us or we are providing services to you. Thereafter, we will keep your personal information:
- To respond to any questions, complaints or claims made by you or on your behalf;
- To show that we treated you fairly;
- To keep records required by law.
We will not retain your personal information for longer than necessary.
European Union Users: Transferring Your Personal Information Out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.,:
- With our offices outside the EEA;
- With your and our service providers located outside the EEA;
- If you are based outside the EEA;
- Where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
If you would like further information, please contact us (see ‘How to contact us’ below).
European Union Users: Your Rights Under the GDPR
For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please contact us (see below: “How to contact us”).
Do Not Track
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Like many websites and online services, we do not currently alter our practices when we receive a “Do Not Track” signal from your browser. To find out more about “Do Not Track” you may visit www.allaboutdnt.com.
Keeping Your Personal Information Secure
We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
Links to Third Party Websites
We do offer links to other websites. When you click on links to other websites, we encourage you to read their privacy policies. Their standards may differ from ours.
How to Complain
Please contact us if you have a complaint. We hope that we can resolve any query or concern you raise about our use of your information.
The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.
Changes to This Privacy Notice
We may change this privacy notice from time to time–when we do we will inform you via an update to this page and the date at the top of this page.
How to Contact Us
Please contact us at support@atvirtualcounsel.com if you have any questions about this privacy policy or the information we hold about you.
