At VSL we do all we can to respect your right to privacy and to protect your personal information. This notice sets out what we do with your information in order to run our business and to serve you as our customer with processing services created using our goods, products and services. Our privacy notice may be updated from time to time; we publish the updated notice on our website.

Who are we?

Our companies are Voice Services Ltd (Company number 3478609) and VSL Networks Ltd (Company number 05413070), collectively referred to as ‘VSL’. References to ‘us’ or ‘we’ are references to VSL.

What is the purpose of this Privacy Notice?

Your privacy is very important to us. The purpose of this Privacy Notice is to explain who we are, the Personal Data we collect, how we collect it and how we use it. In summary, we use very limited Information about you (which may contain an element of Personal Data). What we mean by ‘Information’ is explained in the following paragraph.

What kind of Personal Data do we collect?

The Information we collect is restricted to your name, your company address, your company email address, your company telephone number and, if you provide it, your mobile telephone number. Among these items, the only items on the list that constitutes Personal Data are your company email addresses.

If you trade with us as an individual or an unincorporated partnership then we may collect your address, your email address, your telephone number and if you provide it with your mobile telephone number. All these are considered personal data.

We retain information about your needs in relation to our goods, products and services, and a history of commercial transactions that may have taken place when you have acquired or accessed goods, products and services from us. We keep a history of any support services related to those goods, products and services which you have acquired or accessed, which we may have provided to you from time to time either actively or in response to requests from you.

We also hold the information you provide to us about your communication preferences.

Use of information about your company will still be covered by your product terms.

Where do we collect Personal Data from?

We collect Information from four sources: (1) Companies House and credit reference agencies; (2) your/your company’s website; (3) information provided to us by you/your company; and (4) information that you supply to us either by telephone, email, by service ticket or via the contact form on our website. Our website uses cookies to help us improve the site by providing tracking. To support marketing we draw on analytical information associated with your access to our online presence whether on the internet or social media platforms

Do we collect Personal Data from third parties?

No. We only collect Information from the sources explained above.

How will we use your Personal Data?

We use the Information for five specific purposes: (1) for the legitimate purpose of business to business marketing; (2) to perform our contract if we have entered into a contractual relationship with you; (3) maintaining our business relationship with you and service to you once any contracted deliverables have been supplied; (4) to perform pre-contract activities if we are mutually working towards a contractual relationship; and (5) to respond to specific requests that you make via email or our website.

We may monitor or record calls, emails, text messages or other communications in order to protect you and us.

Whilst we use your information primarily to provide you with goods, products and services, it is also used to better understand your needs and improve the products and services we offer, and for the day-to-day running of our business. We use it to comply with laws and regulations that apply to us and to protect our business, you and our employees.

The core business of VSL is the provision of processing infrastructure to our clients. VSL Networks’ Data Processing activities are contractually limited to the transmission and storage of Customer Data. By Customer Data, we mean confidential data that is owned by the customer and which may contain Personal Data. Under the terms of our contract with you we are forbidden to use, inspect, modify or sample the Customer Data, so we are unable to make any compliance statement on the subject matter, type of Personal Data or categories of Data Subject that may or may not be contained within it. Given the nature of VSL Networks’ services and our contractual relationship with you, only you / your Data Controller is privy to that information. By transmission and storage, we mean that we will transmit Customer Data via leased lines or broadband connections, and store the data on your behalf, all as a ‘black box’ entity.

We may contact you with information relevant to the operation and maintenance of your goods, products and services by a variety of means, including online, mobile app, email, text message, mail and/or telephone. If at any point in the future you change your contact details you should tell us promptly about those changes.

Will we share your Personal Data?

No. The information we collect is solely for our use in connection with the purposes above. However, the goods products and services you obtain from us may require us to involve contracted third parties in their delivery in which case we will only provide those parties with such information as is needed for the successful provision of the goods, products and services you order.

We may share with third parties such as credit reference and fraud prevention agencies, law enforcement agencies or regulators

How do we protect your Personal Data?

To maintain the security of your Personal Data, we implement technical and organisational measures that are appropriate to the risks associated with the loss / illegal Processing of your Personal Data. Our enterprise Information is stored at our head office and at data centres located in the UK. Our employees occasionally work remote from our office for the customer and logistical reasons and are recommended to adopt additional security precautions appropriate to the risk profile created by this way of working for its duration.  Data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

How long will we hold your Personal Data for?

If you have entered into a contract with us, we will retain your Personal Data for a period of six years after our last contact. If we have been in discussions and we have submitted a quotation or proposal to you, we will retain your Personal Data for a period of two years after our last contact. Otherwise, we will delete/redact your Personal Data between three and six months after our last contact or attempted contact.

What are your rights in relation to the Personal Data that we hold?

Subject to any applicable laws, you have the right: (1) to request access to, erasure or rectification of your Personal Data; (2) to ask us to restrict the Processing of your Personal Data; (3) to object to us Processing your Personal Data on specific grounds; (4) to request portability of your Personal Data; and (5) to object to us using your Personal Data for direct marketing purposes. To exercise any of these rights you should contact us using the details below. You also have the right to lodge a complaint with a supervisory body about our use of your Personal Data in the EU state of your habitual residence, place of work or place that the alleged infringement has taken place.

It is important to understand that in some cases, exercising your rights may mean that we are no longer able to provide you with goods, products or services. If you wish to raise a complaint about how we have handled your personal information, you can contact our Data Protection Officer at 0800 093 3000. We hope that we can address any concerns you may have, but you can always contact the Information Commissioner’s Office (ICO). For more information, visit www.ico.org.uk

How can you contact us?

We can be contacted in writing to the Data Protection Officer at Unit 6, Martinfield, Welwyn Garden City AL7 1HG, by email to marketing @vslgroup.co.uk or alternatively via the contact page on our website, which can be found at www.vslgroup.co.uk/contact-us/

May 2018