Welcome to vocL’s privacy policy.
vocL respects your privacy and is committed to protecting your personal data. This privacy policy will inform
you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use our mobile application software (App) and tell you about your privacy rights and how the law protects you.
This privacy policy 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
policy.
This privacy policy aims to give you information on how vocL collects and processes your personal data
through your use of our website or App, including any data you may provide through our website or App
when you purchase or engage with our services and content.
Our website and App are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing
policy 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 policy supplements other notices and privacy policies and is not intended to override them.
VOCL CIC is the controller and responsible for your personal data (collectively referred to as ” vocL “, “we”, “us” or “our” in this privacy policy).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this
privacy policy. If you have any questions about this privacy policy, including any requests to exercise your
legal rights, please contact the data privacy manager using the details set out below.
If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:
Full name of legal entity: vocL CIC
Email address: info@vocL.uk
Postal address: 13 Antill Rd London E3 5BT
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 keep our privacy policy under regular review. This version was last updated on 23/10/2023.
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.
Our website or App 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 or App, we encourage you to read the privacy policy of every website you visit.
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 as follows:
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.
We use different methods to collect data from and about you including through:
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:
Please see the Glossary below to find out more about the types of lawful basis that we will rely on to
process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, 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. Please contact us if you need details about the specific legal
ground we are relying on to process your personal data where more than one ground has been set out in
the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing
and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for
marketing purposes.
You can ask us or third parties to stop sending you marketing messages by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase or experience or other transactions.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or
access cookies. If you disable or refuse cookies, please note that some parts of our website or App may
become inaccessible or not function properly. For more information about the cookies we use, please see here.
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.
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.
We may share your personal data with the parties set out below for the purposes set out in the table
Purposes for which we will use your personal data above.
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.
Some of our third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
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.
Certain services we provide on our App include social networking, chat room or forum features. Ensure
when using these features that you do not submit any personal data that you do not want to be seen,
collected or used by other users.
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 will only retain your personal data for as long as reasonably necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your personal data for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our relationship with you.
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, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see your legal rights below for further
information.
In some circumstances we will 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
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:
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.
If you wish to exercise any of the rights set out above, please contact our data privacy manager, as detailed in the important information and who we are section above.
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 could refuse to comply with your request in these circumstances.
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.
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.
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.
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 obligation means processing your personal data where it is necessary for
compliance with a legal obligation that we are subject to.
HM Revenue & Customs, regulators and other authorities who require reporting of processing
activities in certain circumstances.