Privacy & Cookie Policy

May 2018
Vast Visibility Limited – ICO registered number: Z2630581

Vast Visibility Limited respects your privacy and is committed to protecting your personal data. We take Data Protection seriously because we want you to feel confident about the privacy and security of the personal information you input on our website. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. We follow strict security procedures in the storage and disclosure of your information as required by law.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
DATA SECURITY
DATA RETENTION
COOKIES & OUR COOKIE POLICY
YOUR LEGAL RIGHTS
GLOSSARY


Important Information and Who We Are

Purpose of this Privacy Notice

This privacy notice aims to give you information on how Vast Visibility Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you complete a contact form.

This website is not intended for children and we do not knowingly collect data relating to children.

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

Controller

Vast Visibility Limited is the controller and responsible for your personal data (collectively referred to as, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

Data Protection Officer
Vast Visibility Limited
8 Princes Parade, Princes Dock, Liverpool, L3 1DL
Email address: DPO@vastvisibility.co.uk
Telephone number: 0800 044 3731

If at any point you believe that the information that we hold on you is incorrect you can request to see this information and even have it corrected or deleted. 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.

Subject Access Request

If you require a copy of the information we have concerning you, please make a Subject Access Request to the Data Protection Officer at Vast Visibility Limited, 8 Princes Parade, Princes Dock, Liverpool L3 1DL. Subject to security validation as to the identity of the requester results will be presented as soon as reasonably practical and in any event within one month of the request.

Your Duty to Inform Us of Changes

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.

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 notice of every website you visit.


The Data We Collect About You

Personal data, or 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 data about you which we have grouped together follows:

  • Identity Data includes first name, last name, date of birth, work and educational history.
  • Contact Data includes email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, 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 website.
  • Profile Data includes your interests and preferences.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data 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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If You Fail to Provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.


How is your Personal Data Collected?

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

    • Direct interactions. You may give us your Identity and Contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      • apply for our products or services;
      • subscribe to our service or publications;
      • request marketing to be sent to you;
      • give us some feedback.
    • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.


How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Purposes for Which We Will Use Your Personal Data

We have set out below, a description of all the ways we plan to use 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

 

Purpose/Activity: To receive and respond to enquiries from you

Type of data: Identity, Contact

Lawful basis for processing including basis of legitimate interest: Performance of a contract with you

 

Purpose/Activity: To receive and process job applications

Type of data: Identity, Contact

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (for running our recruitment process)

 

Purpose/Activity: To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

Type of data: Identity, Contact, Technical

Lawful basis for processing including basis of legitimate interest: (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

 

Purpose/Activity: To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Type of data: Identity, Contact, Profile, Usage, Marketing and Communications, Technical

Lawful basis for processing including basis of legitimate interest: 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)

 

Purpose/Activity: To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Type of data: Technical, Usage

Lawful basis for processing including basis of legitimate interest: 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)

 

Purpose/Activity: To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data: Identity, Contact, Technical, Usage, Profile

Lawful basis for processing including basis of legitimate interest: Necessary for our legitimate interests (to develop our products/services and grow our business)

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


Your Personal Data

Vast Visibility Ltd, who for the purposes of the GDPR are the Data Controller administer the website, comply with and are registered under the data protection laws in the United Kingdom and take all reasonable care to prevent any unauthorised access to your personal data.

In the event of the sale of the business, personal data held by Vast Visibility about customers will be transferred along with other assets to the new owners. 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 privacy notice.

We reserve the right to alter or modify this privacy policy statement at any time and in response to changes in applicable data protection and privacy legislation. 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.

We do not transfer your personal data outside the European Economic Area (EEA).

Monitoring

Monitoring or recording of your calls, emails, text messages and other communications may take place in accordance with UK law, and in particular for business purposes, such as for quality control and training; processing necessary for the entering into or the performance of a contract; to prevent unauthorised use of our telecommunication systems and web sites; to ensure effective systems operation; to meet any legal obligation; in order to prevent or detect crime. Please visit the following website for further information www.ico.org.uk
If you have any enquiry about our data protection and privacy policy or practices, please email us –DPO@vastvisibility.co.uk


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.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We use the industry standard secure sockets layer (SSL) 256-bit encryption technology to ensure that all your personal and transactional information is encrypted before transmission. To check that you are in a secure area of our site look at the bottom of your browser and you will see a closed padlock. All this technology and our policies are to safeguard your privacy from unauthorised access/improper use and we will continue to update these measures as new technology becomes available.

IP addresses

Your IP address is a series of numbers which identify a computer (not a person) on the internet. We use IP addresses to help diagnose possible service interruptions and administer our service and website.


Data Retention

Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request it is deleted.

In some circumstances you can ask us to delete your data: see Request erasure below for further information. Even if we delete your personal information it may persist on encrypted backup or archival media for legal, tax or regulatory purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


Cookies & Our Cookie Policy

A cookie is a small text file that is placed on your hard disk by a web page server. Cookies cannot be used to harm your computer, they cannot run programs or deliver viruses to your computer. Cookies are uniquely assigned to your computer, and can only be read by a web server in the domain that issued the cookie to you.

Our cookies don’t store sensitive or personally identifiable information such as your name, address or credit card details: they simply hold a unique ‘key’. We do use encrypted information gathered from them to help improve your experience of the site. For example, they help us to identify and resolve errors, or to help us work out the best user interface for our insurance process.

Cookies can be referred to as session cookies or persistent cookies, depending on how long they are used:

  • Session cookies only last for your online session and disappear from your computer or device when you close your browser.
  • Persistent cookies stay on your computer or device after the browser has been closed and last for the period of time specified in the cookie. These persistent cookies may be checked each time you visit the site where the cookie was generated or, in the case of third-party cookies, from another site that also uses the same service.

Below is a list of the main cookies we use, and what we use them for.

Essential cookies

These are cookies that are enabled for all our customers to ensure that our website works properly.

Google Analytics (any cookie beginning with _utm) – These cookies allows us to collect anonymous information about how visitors are using our website including where they drop-off and which device/browser they came from.

Google Analytics (Demographics and Interest Reporting) – This cookie allows us to use anonymous data from Google’s interest based advertising or third party audience data, including demographic information about our visitors including gender, age group and interests.

Visibility Statistics – We use Visibility Statistics to analyse how users interact with our website and the content found within it. Mouse movements, mouse clicks, page scrolling and text entered into search boxes and website forms may be recorded for statistical reporting purposes and to improve site usability. The data compiled is for internal use only.

Google AdWords, DoubleClick, Bing Ads, OMG, Affiliate Window, VE Interactive, Marin, Facebook – These third party cookies show us how you found our website and which website you came from. This helps us know which of our online marketing channels is most effective. They also allow us to reward some external websites for directing you to us.

Non-essential cookies

We use these cookies for online marketing purposes, the website works without them but we can’t improve our online marketing effectiveness without them. These cookies can be disabled if you don’t want to use them.

AdWords Retargeting – These third party cookies let us serve personalised adverts to you when you’re browsing other websites e.g. reminding you to return to complete your quote. You can control advert personalisation on Google and partner websites here: https://adssettings.google.com/ 

DoubleClick Retargeting – These third party cookies let us serve personalised adverts to you when you’re browsing other websites e.g. reminding you to return to complete your quote. You can control advert personalisation on Google and partner websites here: https://adssettings.google.com/ 

Facebook Retargeting – These third party cookies let us serve personalised adverts to you when you’re browsing Facebook e.g. reminding you to return to complete your quote. You can control advert personalisation on Facebook here:
https://en-gb.facebook.com/ads/settings

The advertisements that you see displayed on our sites are delivered on our behalf by certain third party advertising companies. No information which identifies you, for example your name, address, email address or telephone number, is used to provide this advertising. In order to display advertising most likely to be relevant to you, these third party advertisers may place or recognize a unique cookie on your browser. This cookie does not collect personal information about you nor is it linked to any identifiable information about you. By using the Services you are consenting to the use of these third party cookies for these purposes.


Your Legal Rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). 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. 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 information 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 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. 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.

No fee usually required

  • You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 within one month. Occasionally it may 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

Removing data

  • If you would like us to remove any personal information from our records, then please email us at: DPO@vastvisibility.co.uk Please supply your full name and email address when contacting us in order that we can locate your file. Removal of your data from our records will mean that the renewal reminder service that we provide will no longer take place and you should take alternative steps to ensure that your insurance cover does not unknowingly expire. We will make all reasonable efforts to delete your information from our files.


Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at: customer.services@vastvisibility.co.uk

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the group of companies to which Vast Visibility belongs and who are based in the UK.

External Third Parties

Service providers acting as processors based in the UK who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.

Insurers and insurance brokers who provide quotations for insurance via the website based upon personal information.
Data enrichment organisations as used by insurers for the purposes of providing quotations, including electoral roll search organisations, credit reference and credit scoring agencies.