As your privacy is important to us, VisionLabs (hereinafter referred to as “we” or “us” or “our”) is committed to protect individuals’ personal data in line with the requirements of applicable law, respecting and protecting your confidentiality and privacy. Our commitment applies to all individuals whose personal data may be processed.
This policy is reviewed on an annual basis or earlier as required by changes to legislation or statutory guidance or our business. Any personal information held will be governed by our latest and most up-to-date privacy notice.
1. The personal data we collect
During our relationship with you, and when creating an account with us, we may collect the following information:
- questions, queries or feedback you leave, including your email address if you contact us;
- your email address and subscription preferences when you sign up for our email newsletter;
- your Internet Protocol (IP) address, and details about what web browser version you use;
- information on how you use the site, using cookies;
- personal information contained in your CV sent through our Career section.
Information is collected through the use of our services or other dealings with us through the use of our website, apps, and the account opening application, including the demo sign up forms.
We shall record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide you and our relationship with you. These recordings will be our sole property and will constitute evidence of the communications between us.
Any third parties employed by us (e.g. Service Providers), who handle or obtain personal information, acknowledge the confidentiality of this information, and undertake to respect any individual’s rights to privacy and comply with the relevant data protection law and this privacy notice.
2. Legal Basis for Processing
We may process personal data for one or more Legal Basis depending on the specific purpose for which we are using your data
The Lawful Basis for our processing is:
- to perform our contractual obligations towards you
- to be compliant with applicable legal and regulatory requirements
- to pursue our legitimate interests
Where our use of your personal information does not fall under one of the above-mentioned Lawful Basis, we will require your consent. Such consent shall be freely given by you and you will have the right to withdraw your consent at any time by contacting us, using the contact details set out in this Privacy Notice or by unsubscribing from email lists.
3. Purpose for collecting personal data
The primary purpose for collecting personal information is to provide you with a secure and efficient customised experience. The purposes and/or reasons for processing your personal data are detailed below and include:
- to provide you with the service(s) you have requested and support that you may request
- to provide a more personalised experience
- to enhance security, prevent fraudulent actions, combat security risks
- to deliver targeted marketing, service updates notices, and promotional offers
- to comply with our legal and regulatory obligations
- to enforce agreements with third parties.
4. How we use your personal data
Client information will be treated as confidential and will not be used for any purpose other than in connection with the provision, administration and improvement of the Services, for research and statistical purposes and for marketing purposes. Public Information, or information already possessed without a duty of confidentiality will not be regarded as confidential.
We have the right to disclose Client information (including recordings and documents of a confidential nature, card details) in the following circumstances:
- Where required by law or a court order by a competent Court.
- Where requested by any other regulatory authority having control or jurisdiction over, in whose territory we have Customers.
- to government bodies and law enforcement agencies where required by law and in response to other legal and regulatory requests;
- to relevant authorities to investigate or prevent fraud, money laundering or other illegal activity;
- where necessary in order to defend ourselves or exercise our legal rights to any court or tribunal or arbitrator or Ombudsman or governmental authority;
- to such an extent as reasonably required so as to execute Orders and for purposes ancillary to the provision of the Services;
- to auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes; provided that in each case the relevant professional shall be informed about the confidential nature of such information and commit to the confidentiality herein obligations as well;
- only to the extent required and only the contact details to other service providers who create, maintain or process databases (whether electronic or not), offer record keeping services, email transmission services, messaging services or similar services which aim to assist us collect, storage, process and use Client information or get in touch with the Client or improve the provision of the Services under this Agreement.
- where necessary to defend ourselves or exercise our legal rights to any court or tribunal or arbitrator or Ombudsman or governmental authority.
- to anyone authorised by you.
- Client Information is disclosed in relation to US taxpayers to the Inland Revenue in Cyprus, which will in turn report this information to the IRS of the US according to the Foreign Account Tax Compliance Act (FATCA) of the USA.
5. How your data is stored and for how long
We take your privacy seriously and take all reasonable measures and precaution to protect and secure your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data transmitted, stored or otherwise processed.
We hold personal information in combination of secure computer storage facilities and paper-based files and other records to take steps to protect the personal information. We have several layers of security measures in place, including data encryption, access management procedure, clean desk policy, business continuity and disaster recovery, IT systems risk assessment, physical and logical access segregation, process in case of personal data breach policy etc.
VisionLabs may transfer your data only for the performance of the Purpose within VisionLabs Group which includes VisionLabs B. V. itself and VisionLabs LLC, and other affiliated companies of VisionLabs B. V. For the avoidance of doubt affiliated companies means companies which control, are controlled or under common control with VisionLabs B. V. Control means ownership of more than 50% of voting rights in the Company.
All the companies within VisionLabs Group will keep your data duly secured and will not transfer your outside the VisionLabs Group without your separate consent.
When we consider that personal information is no longer needed, we will remove any details that identify you and securely destroy any records.
6. How we treat your personal data for marketing activities and whether profiling is used for such activities
We may process your personal data to tell you about products, services and offers that may be of interest to you or your business.
The personal data that we process for this purpose consists of information you provide to us and data we collect and/or infer when you use our services. This information helps us to improve our services, customise browsing experience and enable us to inform our clients of additional products, services or promotions relevant to clients.
7. Updating your personal data
If any of your personal information has changed or you became aware that any of your information is inaccurate or incorrect, it is your responsibility to inform us by sending an email to email@example.com .We will not be held responsible for any losses arising from any inaccuracies, deficient or incomplete Personal Data that you provided us.
Our Website can be used to subscribe to newsletters. The data provided during the newsletter registration will be used only for the purposes of sending out the newsletter, provided you have not consented to other use. You can cancel the subscription at any time by using the unsubscribe option provided in the newsletter.
9. Your rights in relation to the use of personal information
Right of access – you have the right to request from us to provide you with a copy of the personal data we hold about you.
Right of rectification – you have the right to request from us to correct the personal data we hold about you if it is inaccurate or incomplete.
Right to be forgotten – you have the right to request from us in certain circumstances to erase, delete or remove your personal data from our records. Provided that these circumstances apply to your case and no exception to this obligation applies (e.g. where we are obliged to store your personal data in compliance with a legal obligation under UK or EU law), we, in our capacity as the data controller, will erase your personal data from our records.
Right to restriction of processing – you have the right to request from us where certain conditions apply, to restrict the processing of your personal data.
Right of portability – you have the right to request from us where certain conditions apply, to have the data we hold about you transferred to another organisation. Where these conditions apply, we will transfer your personal data to another organisation.
Right to object – you have the right to object on grounds relating to your particular situation, to certain types of processing such as direct marketing or 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
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.
Right to withdraw your consent where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before the withdrawal of 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.
In respect to the aforementioned rights, we will respond to requests for personal data and, where applicable, will correct, amend or delete your personal data. You can send the relevant request to the following e-mail address: firstname.lastname@example.org
10. Restriction of responsibility
We are not responsible for the privacy policies or the content of sites to which our website links and we have no control of the use or protection of information provided by the clients or collected by those sites.