Privacy Policy

Contents

Section 1: Introduction

Welcome to Viosmart Marketplace’s Privacy Policy.

www.viosmart.co.uk is a Platform (“Platform”) operated by Viosmart Marketplace Limited (“Viosmart”, “we“, “us” or “our“). We are a registered company in England & Wales under company number 12757135 and have our registered office at Third Floor, Portman House, 2 Portman Street, London, W1H 6DU. We are a Viosmart Holdings Group Company.

We also have separate documents that cover our:

Viosmart respects your privacy and is committed to protecting your personal information. The purpose of this Privacy Policy is to provide you, the user, with details of what information we may hold about you, why we hold it, and how we may use it. This Privacy Policy is expressly incorporated into the Terms and Conditions of this Platform and extends to our offline activities.

Viosmart will act in accordance with current legislation and aims to meet current best practice with regard to the processing of personal information.

By accessing, visiting, browsing, using or attempting to interact with any part of the Platform, you are accepting the practices described in this Privacy Policy.

This Privacy Policy does not apply to the practices of third parties that Viosmart does not own or control.

Section 2: The data we collect about you

Personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

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

Identity Data: this includes first name, maiden name, last name, date of birth, gender, region in which you live and an image of yourself.

Contact Data: this means email address and, if you enter a competition we run, postal address and telephone number.

Technical Data: this 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 and other technology on the devices you use to access this Platform.

Profile Data: this includes data on how much has been spent in a given purchase. Shopping data is provided to us by our affiliated retailers – often via an intermediary such as technology providers, marketing agencies or affiliate networks.

Usage Data: this includes information about how you use our Platform, products and services.

Marketing and Communications Data: this includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal information but is not considered personal information in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. We may also collaborate or engage with third parties who may provide statistical analysis of your personal information to us. Again, this data is not considered personal information in law and does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

If you sign-up using Facebook, we will store a link to your Facebook account and require you to provide the requested permissions (access to your full name and email address). If you deny or retract these permissions, then you will be unable to access your account.

If you enter a competition we run, then we may store information entered on the competition entry form. This is usually just an email address and name, but may also include a postal address and telephone number.

To help us make emails more useful and interesting, we may receive a confirmation when you open an email from us.

We ask that you do not send us or disclose any sensitive information on or through the Platform or otherwise, being personal information relating to: racial or ethnic origins; political opinions; religious or other beliefs; health or medical conditions; trade union membership; sexual orientation; or criminal background. If any sensitive information is freely available or accessible in the public domain, we will not have any obligations to you regarding that information.

Section 3: How we use your personal information

The personal information we store may be used to tailor our service to you. Examples of this include sending you a promotional email based on which retailers you have shopped at using Viosmart. On our Platform, it may involve us highlighting particular retailers based on your history or demographic data.

We may also use your information – including identity/profile, technical and usage data for the purposes of:

  • responding to your enquiries;
  • providing you with goods and services that you request, processing donations and enable you to participate in competitions;
  • sending you marketing communications and other information or materials that may be of interest to you or which you have expressed an interest in receiving;• maintaining our list of contacts;
  • better understanding your needs and assessing the effectiveness of our events, promotional campaigns and publications;
  • understanding how our products and services are being used and to aid the decisions we make;
  • complying with our legal obligations; responding to legal process or requests for information issued by government authorities or other third parties; or in protecting your, our, or others’ rights, such as exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Section 4: Disclosures of your personal information

We do not share your personal details except where necessary to provide our services to you. Examples of where we may do this include:

  • You have entered a competition and have explicitly opted in to receive communications from the participating retailers or charity partners. Only your name and email address are shared.
  • A retailer has requested information for the purposes of fraud prevention or for legal reasons.
  • When we share your information with our staff. However, their use shall be limited to the performance of their duties and in line with the reason for processing. Our employees are required to keep that information confidential and are not permitted to use it for any purposes other than to provide our services, to deal with requests which are submitted to us, or for the purposes of facilitating our use of that information in accordance with this Privacy Policy.
  • Where third party service providers have been engaged by us to perform services on our behalf, such as web-hosting companies, information technology providers, web-development consultants, analytics providers, delivery of goods and services, customer services, marketing and communications services, ticket sales and event hosting.
  • Where we engage with third parties who sponsor or co-sponsor or promote or co-promote an event or a competition, raffle, sweepstake, promotion, charity auction or other activity in which you participate.
  • Where we engage with law enforcement, courts or tribunals, other government authorities or third parties (within or outside the jurisdiction in which you reside) as may be permitted or required by the laws of any jurisdiction that may apply to us; as provided for under contract; or as we deem reasonably necessary to provide our services. In these circumstances, we take reasonable efforts to notify you before we disclose information that may reasonably identify you, unless giving prior notice is prohibited by applicable law or is not possible or reasonable in the circumstances.
  • To protect the rights, property, or safety of Viosmart or others, including exchanging information with other companies and organisations for fraud protection and credit risk reduction.
  • When we engage service providers, advisors, potential transactional partners or other third parties in connection with the consideration, negotiation, or completion of a transaction in which we are acquired by or merged or amalgamated with another company or we sell, liquidate, or transfer all or a portion of our assets.
  • Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.

As we often work with retailers via third parties (such as technology providers, marketing agencies and affiliate networks), “retailers” in the above examples can also include such organisations working on the retailers’ behalf – but only for the prescribed purposes.

When you use the Platform to visit a retailer, you are taken to their website where their own terms and conditions, privacy policies, and cookie policies will apply. This will include tracking your activity and they may use a third party (such as technology providers, marketing agencies and affiliate networks) to do this. The tracking of your activity is required in order for the retailer, and any third parties, to report sales to us. Viosmart is not responsible for any marketing material received as a result of your engaging with retailer websites.

You may have the option to link your account to a business. This enables a business to see how much their employees are raising as a whole. If you choose to link your account, then you give permission for your basic personal information (name and email address) to be shared with the business you select. In addition, the business may have access to anonymised and aggregated shopping and donation data.

We may use a variety of tools and services – including, but not limited to, email marketing tools, Facebook advertising tools, and Google advertising/analytical tools – which may involve uploading and processing your data in order to provide a service to us.

If you signed up to Viosmart via a referral link, the individual whose referral link you used may be able to see basic information about you within their account. This is so that they can see who they have referred and if that referral qualifies them for a reward (as we may reward individuals for referring new users to us).

We do not sell, rent or otherwise share any information with unaffiliated entities except as expressly described in this Privacy Policy, or with your prior permission.

If you do not want us to use your personal information in these ways, please contact us as advised in Section 13 below.

Section 5: The security of your information

The security of your personal information is important to us. We endeavour to follow best practices and fulfil all legal obligations with regards to the security of your personal information.

When you enter personal information on the Platform, we encrypt that information using secure socket layer technology (SSL). All personal passwords you use are encrypted. No credit card information is stored on our servers. We follow generally accepted industry standards to protect the personal information submitted to us from unauthorized access or disclosure, both during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

You acknowledge that you are aware of security and privacy limitations, such as:

(a) the limitation of security, privacy and authentication measures and features; and

(b) that data or information on the Platform or server may be subject to hacking, password theft, electronic fraud and/or contaminated viruses.

It is your responsibility to keep your password safe. If you use Facebook to log in to your account, the same applies to your Facebook access details. We cannot take responsibility if you voluntarily or involuntarily enable someone else to access your account and gain access to any personal information stored. Any transmission of your information is at your own risk. Therefore, we urge all users to exercise caution while using our Platform.

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

You may change your password at any time in your account page.

Section 6: Retention of the information we collect about you

We retain the information we collect for no longer than is reasonably necessary to fulfil the purposes for which we collect the information and to comply with our legal obligations. Following completion of the services provided by us, we will store these records digitally.

Where personal information is retained for the purposes of sharing promotional material, and you no longer want to be contacted by us, please visit your account page where you will be able to opt out or contact us as advised in Section 13 below. Please include your name and email address. Please note that you may still receive service related communications from us.

Section 7: Cookies

In using the Platform, you will provide certain personal information to Viosmart and certain information about you will be collected by “cookies”.

Cookies are small text files placed on your computer by websites that you visit. They are widely used in order to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the Platform and to compile statistical reports on website activity. The information cannot be seen by any other websites (so the information is secure) and it enables our system to recognise you when you visit our Platform again. In doing so, this helps improve our service to you.

Cookies are essential for the proper function of our Platform and services. Cookies need to be enabled in order for you to access your account. Therefore, if cookies are blocked or disabled, you will not be able to log in or access your account.

For more information about how we use cookies, please see our Cookie Policy.

Section 8: IP Addresses

The Platform uses internet protocol (IP) addresses. An IP address is a number assigned to your computer by your Internet Service Provider so you can access the internet. Generally, an IP address changes each time you connect to the internet (it is a dynamic address). Note, however, that if you have a broadband connection, depending on your individual circumstances, it is possible that your IP address that we collect, or even perhaps a cookie we use, may contain information that could be deemed identifiable. This is because with some broadband connections your IP address does not change (it is static) and could be associated with your personal computer. We use your IP address to report aggregate information on use and to help improve the Platform.

Section 9: Links

The Platform contains links to the websites of retailers. Viosmart is not responsible for the privacy practices of other websites. This Privacy Policy applies solely to information collected by Viosmart. In the event that you access any other websites through links provided on the Platform, please note that we are not responsible for the privacy practices of such other websites and advise you to read the privacy statements of each website you visit which collects personal information.

Section 10: Information from children

The Platform is not intended for persons under the age of 16. Viosmart does not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register on the Platform. If you are under the age of 16, please do not attempt to register on the Platform or send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal information to or on the Platform. In the event that we learn that we have collected personal information from a child under the age of 16 without verification of parental consent, we will delete that information as quickly as possible. We encourage parents to monitor their children’s internet usage and/or to use web filtering technology to supervise their children’s access to the internet.

Section 11: Compliance with GDPR

The General Data Protection Regulation (GDPR) is an EU regulation that adds to other regulations (such as the Data Protection Act 2018) regarding how we use your personal information and communicate with you. As a company, we seek to be in compliance with these regulations.

Under the GDPR, we will be the data controller for the personal information that we collect about you.

Access to data: You have the right to request a copy of the personal information we hold about you. You may request this by contacting us (see Section 13 below). We do have the right to refuse unfounded, repetitive or excessive requests.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

We try to respond to all legitimate requests 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.

Right to correction: You have the right, within reason, to correction of the personal information that we hold about you. We will use reasonable commercial efforts to make the changes you request, but it is not always possible to modify database information. To the extent that personal information was provided to third parties, we will not be able to make changes to it. Information may not be completely removed from our database(s) due to technical constraints and the fact that we back-up our systems.

Right to consent: We may use personal information as described in this Privacy Policy, and as detailed in our Terms and Conditions for the use of the Platform, subject to your consent. At the point of sign-up, you can optionally give us consent to communicate with you via email. You can change your decision at any time through clicking the unsubscribe link, available in all promotional emails. Additionally, you can withdraw your consent to such use by visiting your account page where you will be able to opt out or by contacting us as advised in Section 13 below.

Right to be forgotten: You have the right to request that we erase any personal information we hold about you. If you wish for us to remove your personal information, please contact us (see Section 13 below).

If you wish to exercise any of these rights, please contact us as advised in Section 13 below. When making your request please provide:

  • your full name and email address;
  • details of your request and the information you want. Please be as specific as possible, and if it is not obvious, it would be helpful if you could explain why you expect us to hold your personal information.

We may also ask you to provide further information in certain circumstances including to clarify the terms of your request or to confirm your identity.

We rely on the following legal grounds to process personal information:

Performance of a contract: We may need to collect and use personal information to enter into a contract with you or to perform a contract that you have entered into with us.

Legal obligation: We may need to collect and use personal information to comply with legal obligations to which Viosmart is subject.

Legitimate interests: We may use your personal information for our legitimate interests to provide our services and to improve our services. Consistent with our legitimate interests and consents that may be required, we may use personal information for our marketing purposes and other technical information as described in this Privacy Policy.

Section 12: How we may contact you

By signing up to the Platform, you agree to our term and conditions. This includes giving us permission (by opting in) to send you promotional emails relating to Viosmart and other products and services we may offer – unless you do not opt in at the point of sign-up or at a later date.

Examples of such promotional emails include shopping offers from our retailers, or the release of a new feature/product, or the launch of a competition.

You can opt out of our promotional emails using the unsubscribe link that is included in all such emails or by visiting your account page where you will be able to opt out.

Your opt out status does not affect the sending of transactional emails – for example emails relating to accessing your account.

If you contact us, for instance via phone or email, you give us permission to contact you relating to your query. Doing so will not result in your details being added to any promotional email lists.

If you are not signed up to Viosmart, but have entered a competition then you will have agreed to our competition terms and conditions. This includes giving us permission to send you promotional emails relating to Viosmart and other products and services we may offer – unless you do not opt in at the point of entry or at a later date.

If you have provided us with your contact information in person, for example at an industry event, then we may be able to contact you including sending a follow-up email or promotional emails. This will depend on the circumstances in which you provided your information.

Section 13: Who we are and how to contact us

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Contact details:

Viosmart Marketplace Limited

Email address: privacy@viosmart.co.uk

Postal address: Third Floor, Portman House, 2 Portman Street, London, W1H 6DU

Telephone number: 020 8187 6884

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

We are registered under the Data Protection Act, registration no. ZA777182 Should you wish to contact us, please submit an enquiry via privacy@viosmart.co.uk.

Section 14: Changes to this Privacy Policy

If you choose to visit the Platform, your visit and any dispute over privacy is subject to the terms of this Privacy Policy, any Terms and Conditions that we may post on the Platform from time to time, and any agreement between us.

We keep this Privacy Policy under regular review. You should check the Platform frequently to see recent changes. All modifications to our Privacy Policy will be effective upon the Company’s posting such modified Privacy Policy on the Platform.

We recommend that you download or otherwise retain a copy of this Privacy Policy (and any revised version) for your records.

This Privacy Policy was last updated on 21 December 2020.