Privacy policy

 

1. Introduction 

This Privacy Policy sets out how we collect and process your personal data and explains your rights in relation to your personal data. Your privacy is very important to us. For the purposes of applicable data protection legislation, we are the controller of the personal data provided to us or collected by us.    

We are vorteXplore of 22 Chancery Lane, London, United Kingdom, WC2A 1LS.   If you have any questions about this Privacy Policy or wish to exercise any of your rights in relation to your personal data, you can contact us at this address or by email to info@vortexplore.com. 

We reserve the right to update this Privacy Policy from time to time at our discretion. If we do so, and the changes substantially affect your rights or obligations, we shall notify you if we have your email address. Otherwise, you are responsible for regularly reviewing this Privacy Policy so that you are aware of any changes to it. 

2. Data we collect 

From time to time, we may collect personal data about you. By personal data, we mean identifiable information about you, such as your name, email address, mobile and home telephone number.    

Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your account on the Services (an “Account”), if you are an Account holder), and to enable you to enjoy and easily navigate our Services. 

Information you provide to us 

From time to time you may provide to us personal data. This may be because you wish to: 

  • use our website; 

  • purchase our survey diagnostic service; 

  • complete our online form to Contact Us; 

  • apply for a job with us;  

  • provide services to us; or 

  • otherwise contact us including with queries, comments or complaints.   

If you visit our website, you may choose to provide us with your first and last name, email address, phone number, business info such as company name, and number of employees, in order to obtain information about our Services or respond to client service requests. We collect this information only for our marketing purposes and will not share this information with third parties. 

We shall process all such personal data in accordance with this Privacy Policy. When you contact us by email or post, we may keep a record of the correspondence and we may also record any telephone call we have with you.  

Information we automatically collect about you 

When you use our website, we automatically collect and store information about your device and your activities. This information could include: 

  • technical information about your device such as type of device, web browser or operating system;  

  • your preferences and settings such as time zone and language; and 

  • how you arrived at our website, how long you used the website and which services and features you used.  

This analytics data, collected via a JavaScript tag in the pages of our website, is not tied to personally identifiable information.  We use Google Analytics (http://www.google.com/analytics/) for this purpose. 

Some of this information is collected using cookies and similar tracking technologies. If you want to find out more about the types of cookies we use, why, and how you can control them, please see our Cookies Policy.  

Survey Information 

If you are Survey Respondent, we will collect your survey responses and provide them to the vorteXplore Client (defined below) (including its Administrators) all under the direction of the VorteXplore, who is the data controller in the context of any information you provide in connection with a survey. The “vorteXplore Client” is the vorteXplore corporate client or client which is responsible for administering the survey. Unless we tell you otherwise via the Services before you respond to a particular survey, we will provide your survey response without directly identifying you to the applicable vorteXplore Client; however, please be advised that, it is possible that the VorteXplore Client may be able to determine your identity based on the information you include in your survey responses (by way of example, but not limitation, if you include PII in your comments or username). 

3.        Lawful use of your personal data 

 We will only use your personal data where we have a lawful basis to do so.  The lawful purposes that we rely on under this Privacy Policy are: 

  • consent (where you choose to provide it); 

  • performance of our contract with you; 

  • compliance with legal requirements; and 

  • legitimate interests. When we refer to legitimate interests we mean our legitimate business interests in the normal running of our business which do not materially impact your rights, freedom or interests. 

The main reason that we use personal data is to administer your use of the Services in accordance with the vorteXplore Terms of Service.  

We may from time to time need to use your personal data to comply with any legal obligations, demands or requirements, for example, as part of anti-money laundering processes or to protect a third party’s rights, property, or safety.   

We may also use your personal data for our legitimate interests including to improve our services and in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company; to deal with any client services you require; for audit purposes and to contact you about changes to this Privacy Policy. 

4.        Who do we share your data with? 

We do not collect any personal data as part of our survey. 

As described above, you may share your personal data with us as an Account Holder, for instance. For our legitimate interests we may share your personal data with any other service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions, including payment providers,  IT service providers, accountants, auditors and lawyers.     

We shall provide our service providers, sub-contractors and agents only with such of your personal data as they need to provide the service for us and if we stop using their services, we shall request that they delete your personal data or make it anonymous within their systems. 

5.        Where we hold and process your personal data 

We may use the services of third parties who are located outside of the UK and the European Economic Area (EEA). Some or all your personal data may be stored or transferred outside of the UK and the EEA for any reason, including for example, if our email server is located or if any of our service providers are based outside of the UK or the EEA.

Where your personal data is transferred outside of the UK and EEA, it will only be transferred to countries which provide adequate protection or to a third party where we approve transfer mechanisms to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the third party is subject to the Privacy Shield (for transfers to US-based third parties).  We only use the services of providers who are recognised as market leaders in their field.  This includes but is not limited to the following organisations which subscribe to the Privacy Shield framework: 

  • Amazon Web Services for the cloud storage of data and hosting of our app 

  • Google - Google Analytics, GSuite email, GDrive 

  • Microsoft – Microsoft Azure for the use of Office365 

  • MailChimp - for the secure transmission of marketing emails 

6.        Security 

The security of your personal information is important to us. We shall process your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage.  In particular, access is restricted to employees who need to know your personal data, and we use appropriate password protection and appropriate strong encryption electronic measures within our electronic data management systems.  

 If there is a security breach, we will do all that we can as soon as we can to stop the breach and minimise the loss of any data. 

7.        Marketing 

You may consent to receive marketing email messages from us.  You can choose to no longer receive marketing emails from us by contacting us or clicking unsubscribe from a marketing email.  Please note that it may take us a few days to update our records to reflect your request. 

We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.  

8.           Cookies 

We use a number of different cookies on our website. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance. 

The following describes the cookies we use on this website and what we use them for. Currently we operate an ‘implied consent’ policy which means that we assume you are happy with this usage. If you are not happy, then you should either not use this website, or you should delete  

cookies having visited the website, or you should browse the website using your browser’s anonymous usage setting (called “Incognito” in Chrome, “InPrivate” for Internet Explorer, "Private Browsing" in Firefox and Safari etc.).  If you block cookies, for the most part the websites should continue to operate normally, however there may be some areas where you may not be able to take full advantage of the website’s functionality. 

You can disable Cookies in your web browser. Information can usually be found in your Web Brower’s help section. 

9.     Persistent cookies for website performance & analytics 

We use third-party analytics services, such as Google Analytics to collect and analyse non-directly identifying personal information. We use these to understand how the website and app are being used in order to improve the user experience. User data is all anonymous.  You can find out more about Google’s position on privacy with regards to its analytics service at 

http://www.google.co.uk/intl/en/analytics/privacyoverview.html. 

In addition, Google Analytics provides you with the ability to opt-out of its tracking services. Details of such opt-out are available at https://tools.google.com/dlpage/gaoptout/. Opting-out of the Google Analytics services will affect only the collection and use of your data by Google Analytics, not by any other party. 

10.           External Web Services 

We may use external web services on the vorteXplore websites, mostly to display content within our web pages. For example to show videos we may use YouTube. This is not the only service we use, or might use in the future, when embedding content, but it is the most common. We cannot prevent these websites, or external domains, from collecting information on your usage of this embedded content. If you are not logged in to these external services then they will not know who you are but are likely to gather anonymous usage information e.g. number of views, plays, loads etc. 

11.           Email Tracking 

Most standard emails that we send you have no tracking in at all.  We use Mailchimp for our marketing emails. Some marketing and all platform emails we track, at an individual level, whether the user has opened and clicked on the email. We rarely use the latter information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. If you want to be sure that none of your email activity is tracked then you should opt out of vorteXplore's marketing emails which you can do at the bottom of every email you receive. 

12.           Surveys and Contests 

From time to time our website may request information from users via surveys, contests or for a particular service (e.g. newsletter). Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested will include contact information (as supplied to the website during registration) and supplementary information on your interests, opinions and preferences (e.g. feedback on the VorteXplore service). We will use the contact information to notify winners. We will not publish winners' details on the website though on request we will provide details of any winner's name. If the survey or contest has a sponsor then we may share information given by entrants with the sponsor, but only with the user's consent. 

13.           Testimonials 

We display personal testimonials of satisfied users and clients on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at info@vortexplore.com. 

14.        Your rights 

You have a number of rights under applicable data protection legislation. Some of these rights are complex, and not all of the details have been included below. Further information can be found here 

  • Right of access:  You have the right to obtain from us a copy of the personal data that we hold for you. 

  • Right to rectification: You can require us to correct errors in the personal data that we process for you if it is inaccurate, incomplete or out of date. 

  • Right to portability: You can request that we transfer your personal data to another service provider. 

  • Right to restriction of processing:  In certain circumstances, you have the right to require that we restrict the processing of your personal information. 

  • Right to be forgotten: You also have the right at any time to require that we delete the personal data that we hold for you, where it is no longer necessary for us to hold it.  However, whilst we respect your right to be forgotten, we may still retain your personal data in accordance with applicable laws.  

  • Right to stop receiving marketing information: You can ask us to stop sending you information about our services. 

We reserve the right to charge an administrative fee if your request in relation to your rights is manifestly unfounded or excessive. 

If you have any complaints in relation to this Privacy Policy or otherwise in relation to our processing of your personal data, please tell us. We shall review and investigate your complaint and try to get back to you within a reasonable time.  You can also contact the Information Commissioner, see www.ico.org.uk or if you are based outside of the United Kingdom, please contact your local regulatory authority. 

15.        Retention of personal data  

Subject to the provisions of this Privacy Policy, we will retain personal data in accordance with applicable laws and industry practice in the software sector.  

We endeavour to keep personal data only for as long as is necessary. However, we have legitimate interests for retaining your personal data after we have provided our service including: 

  • to deal with any follow up queries or questions that you might have; 

  • to establish, exercise or defend any legal claim that may arise. 

We may also be required to retain personal data for a particular period of time to comply with legal, auditory or statutory requirements, including requirements of HMRC in respect of financial documents. 

Please note that if you ask us to remove you from our marketing list, we shall keep a record of your name and email address to ensure that we do not send to you marketing information. 

16.        General  

If any provision of this Privacy Policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.   

This Privacy Policy shall be governed by and construed in accordance with English law and you agree to submit to the exclusive jurisdiction of the English Courts. 

Last updated: May 2021