ValidOrbit customer privacy notice

Contact details

Email: info+privacy@validorbit.com

ICO Registration: ZC186915

What information we collect, use, and why

We collect or use the following information to provide services and goods, including delivery:

• Names and contact details
• Purchase or account history
• Payment details (including card or bank information for transfers and direct debits)
• Account information
• Call recordings
• Records of meetings and decisions

We collect or use the following information for service updates or marketing purposes:

• Names and contact details
• Records of consent, where appropriate

We collect or use the following information to comply with legal requirements:

• Name
• Contact information
• Financial transaction information
• Any other personal information required to comply with legal obligations

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details
• Purchase or service history
• Call recordings
• Customer or client accounts and records
• Correspondence

Lawful bases and data protection rights

Under UK data protection law, we must have a "lawful basis" for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO's website.

Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO's website:

• Your right of access — You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for.
• Your right to rectification — You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete.
• Your right to erasure — You have the right to ask us to delete your personal information.
• Your right to restriction of processing — You have the right to ask us to limit how we can use your personal information.
• Your right to object to processing — You have the right to object to the processing of your personal data.
• Your right to data portability — You have the right to ask that we transfer the personal information you gave us to another organisation, or to you.
• Your right to withdraw consent — When we use consent as our lawful basis you have the right to withdraw your consent at any time.

If you make a request, we must respond to you without undue delay and in any event within one month. To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Our lawful bases for collecting or using personal information to provide services and goods:

• Contract — we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.

Our lawful bases for collecting or using personal information for service updates or marketing purposes:

• Consent — we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
• Legitimate interests — we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: we need to be able to contact our customers who have previously booked or used our services, in order to provide service updates or follow-ups. These communications would be specifically relevant to the services they have engaged from us.

Our lawful bases for collecting or using personal information for legal requirements:

• Legal obligation — we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.

Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims:

• Contract — we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
• Legitimate interests — we're collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are: handling queries and complaints is a necessary and expected part of delivering our services.

Where we get personal information from

Directly from you.

How long we keep information

We retain different types of personal information for different periods, depending on the purpose for which it was collected and any legal obligations we are subject to.

• Booking and contact details (collected via Microsoft Bookings): 3 years from the date of last contact.
• Client account information and correspondence: 6 years from the end of the client relationship, in line with the Limitation Act 1980 (the window for contractual claims).
• Payment and financial records: 6 years, as required by HMRC.
• Marketing consent records: for the duration of the marketing relationship, plus 1 year, to demonstrate consent if required.
• Call and meeting recordings: up to 2 years.

When personal information is no longer required, we delete or securely destroy it. You can request deletion of your personal information at any time by contacting us at info+privacy@validorbit.com, subject to any legal obligations that require us to retain it.

Who we share information with

We use the following data processors who handle personal information on our behalf:

• Microsoft Corporation — They provide our online appointment booking system (Microsoft Bookings), which collects and stores the names, phone numbers, email addresses and any notes from individuals who book meetings with us.

Sharing information outside the UK

Where necessary, we will transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.

Organisation

Microsoft Corporation

Category

Cloud technology and software services provider

Country

United States of America

Transfer mechanism

Addendum to the EU Standard Contractual Clauses (SCCs)

Organisation

ValidOrbit Ltd

Category

Internal employees / remote workers

Country

United States of America

Transfer mechanism

An exception listed in UK GDPR — Article 49(1)(b): transfer necessary for the performance of a contract

Where necessary, our data processors may share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.

Organisation

Microsoft Corporation

Category

Cloud technology and software services provider

Country

United States of America

Transfer mechanism

Addendum to the EU Standard Contractual Clauses (SCCs)

How to complain

If you have any concerns about our use of your personal information, you can make a data protection complaint to us at info+privacy@validorbit.com.

If you remain unhappy with how we've used your data after raising a complaint with us, you can also complain to the ICO.

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Helpline: 0303 123 1113. Website: ico.org.uk/make-a-complaint