- Thank you for trusting us to be responsible for your personal data, which we want you to know that we take seriously.
- This policy informs you about how each company looks after your personal data when you interact with our website https://vyta.com (regardless of where you visit the site from) (our website) or access or use any of our services (the Services).
- It also informs you how we will look after your personal data when, and about your privacy rights and how the law protects you. It does not cover any third-party websites you have used to access our websites or any third-party websites that you access from them.
- It applies to all processing of personal data undertaken by us other than processing of personal information in the context of recruitment and employment, which is dealt with under separate internal policies.
It is important that you read this policy so that you are fully aware of how and why we are using your data.
2. Who we are?
- Contact Details
Our full details are:
Full Name of Legal Entity: Vyta Secure Ltd, a company incorporated in Northern Ireland under company number NI040520
Email Address: firstname.lastname@example.org
Postal Address: Unit 1 Mallusk View, Central Park, Newtownabbey, Northern Ireland, BT36 4FR
ICO Registration Number: Z1628515 (this is the number under which we are registered with the ICO for the processing of personal data)
- Under the UK General Data Protection Regulation or the EU General Data Protection Regulation (collectively or separately, as applicable, GDPR) and other relevant data protection legislation, we act as both a controller (i.e., where we make decisions) in relation to your personal data that we collect, as well as a processor (i.e., process data broadly in accordance with your instructions.
When we act as a Processor: Whenever Vyta acts as a processor, or a sub-processor, we will be restricted in the manner and purpose for which we can use personal data (including where applicable in the manner outlined in this policy) and we will also be subject to other obligations under data protection legislation.
When we act as a Controller: By contrast, when Vyta collect personal data and determine the purposes and means of processing that personal data – for example, when we store information for customers collected through administration or services access processes or contact information as explained below – we act as a controller.
- Third-Party Links
3. What personal data do Vyta Group process?
- Information you supply to us:
- General personal data – This is personal information about you that you may share with us by online forms, on our websites, through email, through the post, on the telephone, when your complete customer surveys, engage with our customer services team, engage Vyta Group to provide Services and/or products or by any other means.
- Typically, when you generally interact with Vyta Group you may provide information about yourself, as well as other data about your business, including your full name, job title, billing address, business name, personal and/or business email address, telephone and/or mobile phone number and other contact details. You may provide similar information where you contact us, sign up to events or sign up to our newsletter.
- Financial Details: Where you are a supplier you may provide us with your financial details to facilitate payments by us to you or a customer contacting us to provide your financial details in the context of any returns or overpayment, and we may collect these financial details. All such details will be kept securely.
- Verbal Information: If you provide verbal personal information that you give us consent to use you will have such consent confirmed back to you in writing.
- Marketing Information: You may also communicate your preferences in receiving marketing from us and our third parties and your communication preferences (including details you provide when you opt-in to receive marketing communications from us).
- Third Party Data: Where you are sharing personal data that does not directly relate to you (e.g., your representatives that legally act on your behalf), you must ensure you have the consent to do so and have shared this policy with that person/those people, including where you are acting to register other individuals on their behalf.
- General personal data – This is personal information about you that you may share with us by online forms, on our websites, through email, through the post, on the telephone, when your complete customer surveys, engage with our customer services team, engage Vyta Group to provide Services and/or products or by any other means.
- 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 with you (for example, to provide you with Services and/or products). In this case, we may not be able to fulfil any order you place with us, but we will notify you if this is the case at the time.
- Personal data we collect
- Technical Data from our Website: We may use certain technical services to gather technical data online whenever you use our websites including information about your device and your visits to our websites such as, geographical location, browser type, referral source, length of visit and pages viewed.
- We may collect this data using cookies and other similar technologies. There is (currently) no login functionality on our websites, so you will not be personally identifiable from such data
- An internet service provider(“ISP”) has a record of the temporary “dynamic IP address” assigned to a particular user’s device (potentially identifiable data) and a website provider has a record of the web pages accessed by that dynamic IP address (but no other data that would allow identification of the individual).
- Our ISP’s may temporarily record your IP address which has the potential personally identify and individual from such data.
- A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added, and the cookie helps analyse web traffic or lets you know when you visit a particular site.
- Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website to tailor it to customer needs.
- We only use this information for statistical analysis purposes and then the data is removed from the system.
- Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
- You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
- Personal data we may receive from third parties
- Device Data: analytics providers such Google Analytics (in respect of our websites) based inside the EU.
- Social Media: publicly available information through social media sites, such as Facebook, LinkedIn, Twitter, and Google. This includes where you have responded to a promotional item or offer from us through social media facilities, in which case we may receive profile information about you which can include your name, address, telephone number(s) and/or your business contact details. This information would be used to respond to your interest, to fulfil a request from you and/or to send you future information and offers, where you have given clear consent to do so.
- Publicly Available Information: As a general Vyta Group customer, we may collect personal information about you from other publicly available sources. This can include your name, address, and other publicly available information. As far as passible, we ensure that where any third parties are involved in suppling such information, that they are compliant to do so.
- Other: from time to time, we may receive personal information from other sources. We will always endeavour to ensure such information is provided from reputable sources, who are GDPR compliant to do so.
- Keeping your personal data up to date
- It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
4. What Information Is Not Collected?
- Other than as captured incidentally through our Services or Footage from our CCTV, we do not intentionally collect sensitive personal data or special category data (including details about your race or ethnicity, religious or philosophical beliefs, medical information, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data, social security numbers). Nor do we collect any information about criminal convictions and offences.
- If you’re a child under the age of 16 (or are otherwise younger than the legal age limit required in the country in which you reside), you may not provide personal information to us via our websites. Vyta Group does not knowingly collect information from or direct any of our content specifically to children under relevant ages.
- If you are a child aged between 16 and 18 using our websites from the UK or European Union, you must have informed your parents or guardians of this, of the terms of this policy, and have their consent to do so.
5. How Is Information Used?
- 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 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.
- We only use Footage from CCTV in the following circumstances:
- For the purposes of monitoring, detection and prevention of health and safety incidents.
- To provide internal & external security within the Vyta group sites
- Where we need to comply with a legal or regulatory obligation
- Footage throughout our sites is processed in real time, we endeavour not to retain any Footage for longer than is necessary to fulfil the purposes we collected it for, and in any event, to delete any Footage no later than 100 days following the initial recording, unless its use is required in the investigation of a crime or incident.
- Generally, we do not rely on consent as a legal basis for processing your personal data other as set out below in relation to marketing and testimonials. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
7. Our Standard Business Operations:
- To provide the services and any other responsibilities that we contract to do so with you
- To provide you with information that you request from us.
- To confirm your identity as a natural living person, and as part of our billing, payments, and recovery processes.
- We may also use contact information to notify you of any issues which might impact the provision of our Services and/or products.
- We maintain multiple contact lists (with email addresses and other information) to allow us to communicate with individuals who do business with us or who have expressed an interest in our Services and/or products.
- We may contact you to respond to requests that you make, notify you of changes to the Services and/or products, for marketing purposes, or to otherwise inform you of information related to our business.
- You will only receive marketing communications from us if you have opted to receive them. This includes where you have consented to being contacted by us by email or telephone. You can opt in over the phone, by email, or online. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us, as appropriate, at any time.
- Where you opt out of receiving marketing messages, this will not apply to personal data provided to us because of your engagement with us to provide Services and/or products to you.
- We will never sell your personal data to any third party (as noted below).
- We may post customer testimonials and comments on our websites or other platforms, which may contain personal data. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.
10. 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us or the DPO.
- 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.
11. Legal Requirements
- We will keep and use your data in terms of any legal or regulatory requirements that we have and can use your data to protect our legal position, if legal action is required, including the recovery of any outstanding debts.
- By way of further example, we will share your personal data with the relevant agencies and without notice, where we are requested to or suspect fraudulent activities, money laundering, terrorist related activities.
12. Website Administration and Customisation
- We may use the information we collect about you for a variety of websites administration purposes, and customisation purposes. For example, we use your information to process your registration request, provide you with services and communications that you have requested, send you email updates and other communications, customise features and advertising that appear on our websites, deliver our websites content to you, measure Website traffic, measure user interests and traffic patterns, and improve our websites and the services and features offered via our websites.
13. Aggregated or Non-Identifying Information
- Non-identifying information includes information collected from or about you that does not personally identify you – including aggregated information. Vyta Group treats IP addresses, log file information, anonymised feedback, user agent strings, computer IDs, and related information as non-identifying information, except if applicable law suggest us to do otherwise. Vyta Group may use non-identifying information for any purpose.
- Certain jurisdictions, including the United Kingdom and the European Union, may deem IP addresses and/or Unique IDs, to be personal data. Accordingly, for persons in such jurisdictions, our use of Non-Identifying Information as described in this policy should be assumed to include IP address and Unique ID data.
14. What Information Is Shared?
- We do not disclose personal data outside Vyta Group, except in the situations listed in this section or in the section below on Compelled Disclosure, but may have to share your personal data with the categories of processors or controllers set out below for the purposes set out in in above or otherwise below:
- with HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances (excluding Footage – unless we are subject to a Compelled Disclosure).
- with third party purchasers, if we buy, sell, or merge any business or assets of our business and are required to share data as part of the buying, selling or merger agreement or if our assets are acquired by a third-party, and data is transferred as part of the purchased assets. If any such change happens, we will ensure that it is under terms that preserve the confidentiality of your personal data, and we will notify you on our websites or by email before any transfer of your personal data.
- with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, where they have a need to know same for any of the purposes set out above (excluding Footage).
- with reputable and trusted third parties where we have asked them to contact you on our behalf, where you have given us consent, it is part of our contractual agreement, is a legal requirement or there is clear legitimate interest between us (these services may include sending you email, calling you by telephone, sending you information through the post etc.) (excluding Footage).
- with specific selected third parties, determined by us, if you breach any agreement with us, including to enforce our rights against you, including credit-reference agencies, debt-collection firms or service providers, solicitors or barristers and law enforcement agencies (if applicable) (excluding Footage); and
- with service providers acting as processors based in the European Union & United Kingdom by way of an adequacy decision and our Makor server based in the US by way of the EU standard contractual clause agreements and International Data Transfer addendum to the EU commission standard contractual clauses, of who provide IT and system administration services, including for the performance of our contract with you, as set out below: When we transfer your data to our service providers, we remain responsible for it:
- with email marketing services to send marketing emails where you have opted in to receiving them. You can unsubscribe directly from any mailing list using the unsubscribe links provided within emails (excluding Footage).
- with analytical service providers to analyse our websites’ traffic to improve Services and/or products (excluding Footage).
- with processors offering software tools, or EU, UK and US based external servers (including externally provided original and backup servers), that are used to store personal data provided by you on our behalf (our current servers are maintained by Azura, and Makor whose privacy policies are available at https://privacy.microsoft.com/en-gb/privacystatement & https://www.makorerp.com/privacy-notice/ network data transmission, specifically transfers occur via point-to-point data streams through a network
- 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 the minimal personal data required for the specified purposes, in accordance with our instructions, where they have agreed to privacy restrictions similar like our own policy.
- We do not share, sell, rent, or trade personal data with third parties for their commercial purposes. We may also share personal data with your permission, so we can perform services you have requested.
15. How Is My Information Secured?
- Vyta Group takes all measures reasonably necessary to protect personal data from unauthorised access, alteration, or destruction, maintain data accuracy and help ensure the appropriate use of personal data. We follow generally accepted industry standards to protect the personal data we hold, both during transmission and once we receive it.
- 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 duties 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 have various security measures in place to ensure your data is secure
16. How Is Information Collected and Stored Globally?
- Information that we collect will be stored and processed in the United Kingdom the European Union and the United States in accordance with this policy. However, we understand that we have customers from different countries and regions with different privacy expectations and local legal requirements, and we try to meet those needs and requirements.
- We provide the same standard of privacy protection to all our users around the world, regardless of their country of origin or location, and we are proud of the levels of notice, choice, accountability, security, data integrity, access, and recourse we provide. We work hard to comply with the applicable data privacy laws wherever we do business. Additionally, we require that if our vendors or affiliates have access to personal data, they must comply with applicable data privacy laws, including signing data transfer agreements such as EU standard contractual clause agreements or International Data Transfer addendum to the EU commission standard contractual clauses, where required by law.
- In particular:
- we provide clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data and if applicable. Where consent is not the applicable ground for processing, we will ensure that it has an appropriate ground for processing any personal data (including but not limited to contractual obligation or legitimate interest).
- we collect only the minimum amount of personal data necessary unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing.
- we offer you simple methods of accessing, correcting, or deleting the data we have collected.
17. What Happens If I Have a Complaint?
- If you have concerns about the way Vyta Group is handling your personal data, please let us know immediately. We want to help and there are several ways available that you can contact us. You may also email us directly at email@example.com in relation to data held by Vyta group, and with the subject line “Data Privacy”. We will respond within 30 days at the latest, unless required to respond earlier under relevant law.
- We have appointed a data protection officer (DPO) to oversee compliance with this privacy notice. Where this policy refers to circumstances in which you can contact us, you may also contact the DPO (Richard Duckett) directly at DPO@vyta.com.
- If you are a data subject based in the UK or European Union, you may 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 (ico.org.uk), or other competent supervisory authority of an EU member state if the websites is accessed outside the UK. We would appreciate the chance to deal with your concerns before you approach such bodies so would ask that you, please contact us in the first instance.
18. How Do You Respond to Compelled Disclosure Requirements?
- Vyta Group may disclose personal data or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar governmental order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.
- In complying with court orders and similar legal processes, Vyta Group strives for transparency. When permitted, we will make a reasonable effort to notify users of any disclosure of their information, unless we are prohibited by law or court order from doing so, or in rare, exigent circumstances.
19. How Can I Access My Own Personal Information?
- If you’re already a user, you may access, update, alter, or delete your basic user profile information by editing your user profile or contacting us.
- Under certain circumstances, where you are a citizen of the European Union or UK, you have rights under data protection laws in relation to your personal data under GDPR.
- 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.
- Please 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 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 Services and/or products to you. We will advise you if this is the case at the time you withdraw your consent.
- If you wish to exercise any of the rights set out above, please contact us or the DPO.
- 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.
- Where you exercise one of your rights, we may need to request specific information from you to help us confirm your identity and ensure your right to exercise such 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.
- 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 several requests. In this case, we will notify you and keep you updated.
20. Data Retention and Deletion
Personal Data Generally
- We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
- To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
- We will keep your personal data for the term you have consented to, the contracted term between us where there is a legitimate interest for us to remain in contact with you, or for the legally required period, whichever is the longest.
- By law we must keep basic information about any of our customers (including contact, identity, financial and transaction data) for six years after you cease being a customer for tax purposes. For the purposes of contract administration, we will also store all data if the contract you have placed through us endures and for the six-year limitation period thereafter in case you raise any claims in relation to any Services and/or products you have purchased from us.
- 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.
- If you would like to initiate deletion of your personal data held by Vyta group, you may do so by e mailing firstname.lastname@example.org. Please place deletion request in the subject of the e mail and confirm what Data you require deleting within the e mail, and which part of Vyta group are holding the Data. As above, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, maintain security, and enforce our agreements, but barring legal requirements, the timeframe above will be observed for deletion.
21. How Do You Communicate with Users?
- We will use your email address to communicate with you, if you’ve given us permission, and only for the reasons you’ve permitted. Emails by default are not disclosed with other users. This will not change how we contact you, as we always utilise your primary email address.
- Depending on your email settings, Vyta Group may occasionally send notification emails about new Services and/or products, requests for feedback, important policy changes, or to offer customer support. We also send marketing emails, including ones featuring, services and products offered by our commercial partners, but only with your consent. There’s an unsubscribe link located at the bottom of each of the emails we send you.
- Our emails might contain a pixel tag, which is a small, clear image that can tell us whether you have opened an email and what your IP address or recipients address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. If you prefer not to receive pixel tags, please opt out of marketing emails
- If there are material changes to this policy or in how we use your personal data, we will prominently post such changes prior to implementing the change. We encourage you to periodically review this policy to be informed of how we are collecting and using your information.
- We keep this policy under regular review, for example, to reflect changing business circumstances and legal developments.
- Although most changes are likely to be minor, it may change and if it does, these changes will be posted on this page. Otherwise, any changes shall be applicable without further notice.
- This version one of this policy was last updated in May 2022 and historic versions can be obtained by contacting us or the DPO.
23. How Can I contact Vyta?
- This policy shall be governed by and interpreted in accordance with the laws of Northern Ireland, and you irrevocably agree that the courts of Northern Ireland shall have exclusive jurisdiction to settle any dispute which may arise out of, under, or in connection with this policy.