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Vidya Holdings Ltd | Privacy Policy

This Privacy Notice Was Last Reviewed On 6th January 2021

Introduction

For the purpose of this Privacy Policy "you" or "your" means the representatives or end users of any of our customers, vendors or visitors accessing our Website (as defined below), "we" or "us", "our" means Vidya Holdings Ltd, with registered office at Unit 4 Holford Yard, Bevin Way, London, England, WC1X 9HD and registration number 11036007.

This Privacy Policy together with the Vidya Holdings Ltd Terms and Conditions available at Terms and Conditions and any other documents referred to in it sets out the basis on which any Personal Data we collect from you, or that you provide to us, will be processed by us. This Privacy Policy also sets out how you can instruct us if you prefer to limit the use of that Personal Data and the procedures that we have in place to safeguard your privacy. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

(1) Important Information And Who We Are

This Privacy Policy applies to all Personal Data we process as a controller from the representatives or end users of any of our customers, vendors or visitors. Under current Data Protection Legislation (the General Data Protection Regulation (EU) 2016/679 (“GDPR”)) and the Data Protection Act 2018 (“DPA”) as applicable in the United Kingdom, the data controller is Vidya Holdings Ltd. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (see section 11 below), please contact us using the details set out below:

  • Full name of legal entity: Vidya Holdings Ltd
  • Email address: hello@vidyahealth.com
  • Postal address: Unit 4 Holford Yard, Bevin Way, London, England, WC1X 9HD

You have the right to make a complaint at any time to the supervisory authority for data protection issues, the Information Commissioner’s Office of the United Kingdom 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.

(2) Changes To The Privacy Policy And Your Duty To Inform Us Of Changes

We keep our Privacy Policy under regular review. Please check back frequently to see any updates or changes to our Privacy Policy. 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.

(3) Third-party Links

The Website may include links to third-party websites 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.

(4) The Data We Collect About You

This is information that you give us by instructing us to provide you with the services, accepting our online Terms of Use, registering an account on our Website. It includes information relating to when you report a problem with our Website. The information you give us may include your name, email address and phone number, financial and credit card information.

You are responsible for ensuring that you are authorised to share all such information with us for the purposes described in Section 6 of this Privacy Policy and that you only provide such data to us in accordance with Data Protection Laws.

We may collect, use, store and transfer different kinds of Personal Data about you such as:

  • Identifying Data includes surname and first name, mailing address, email address, phone number and login details.
  • Professional Details includes company name, company number, company address, job title, post, position and business sector.
  • Technical Data includes internet protocol (IP) address used to connect your computer to the Internet, your login data, browser type and version, time zone setting and location, browser type and version, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Website
  • Usage Data includes information about how you use our Website.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Unless we obtain your informed consent or it is otherwise required by law or in connection with a contract, we have with you, we do not collect any Special Categories of Personal Data, nor do we collect any information about criminal convictions and offences.

(5) How Is Your Personal Data Collected?

(a) Information We Collect About You Through forms, registration or your interactions with us

Vidya Holdings Ltd collects Personal Data either directly from the representatives or end users of any of our customers, vendors or visitors through forms filled in by the individuals on Vidya Holdings Ltd's Website, during the registration process or when our customers’ representatives or end users interact with us.

(b) Information We Collect About You Through Our Website

Regarding each of your visits to our Website we will automatically collect the following information:

  • Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
  • The information you give us may include your name, address, e-mail address and age, username, password and other registration information, financial information, your phone number, the device's phone number and the device unique identifier.
  • Records of communications between you and us relating to services provided by us to you. If you contact us, whether the Website or otherwise we may keep a record of that correspondence. For example, if you submit a query, a complaint, report a problem with our service, Website, or otherwise liaise with our customer service, technical support or any other department in our company.

Information we collect about you and your device. Each time you visit our Website we may automatically collect the following information:

  • Technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting (“Device Information”).
  • Details of your visits to our Website including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access (“Log Information”).
  • Location information. We also use GPS technology to determine your current or past location (the “Location Information”). Some of our location-enabled Services require your Personal Data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by sending us an email to hello@vidyahealth.com. Information we receive from other sources (“Third Party Information”). We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.
  • We may check some of the information that you provide against third party databases to confirm that it is accurate.
(c) If You Fail to Provide Personal Data

Vidya Holdings Ltd will indicate on our forms those data fields which are required for our services to function using the symbol: “*”. If users do not fill in the required fields specified above, they will not be able to sign up and receive the services offered by Vidya Holdings Ltd.

(6) How We Use Your Personal Data

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 (each known as a “lawful basis”):

  • Where we need to perform the contract we are about to enter into or have entered into with you. We may use and share Personal Data to comply with legal obligations and where necessary in relation to your contract with us (either through accepting our online Terms or otherwise) or because you have asked us to do something so that we can enter into a contract with you.
  • Where we need to provide you with assistance in relation to your queries.
  • 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 obligation, for example we may process your Identity, Contact, and Financial Data to comply with laws on money laundering prevention and crime or financing terrorism processes.
  • To provide our services to you and to other customers.

    We use Personal Data to provide our services to you through the Website, including without limitation: forwarding information to you, keeping records and making communications with you to provide customer support; to process and complete requests for information; to administer our Website; and for internal operations, including troubleshooting, data analysis, research and statistical purposes.

    We may also combine the information we collect from you with information we collect from other sources and other customers. We will use the combined information for the purposes of providing the services to you and our other customers. The combined information will primarily be aggregated and anonymised (see “Aggregated Data” below for further detail).

  • To improve our Website and services.

    We also may use Personal Data to improve our Website and ensure that content from our Website is presented in the most effective manner for you. This may include how we prioritise and display content and what features to build or improve.

  • To Contact You.

    We may use your Personal Data to send e-mail communications, for example notifications about our Website and services and to notify you of any changes to our service.

  • To contact you about other services or offers you may be interested in.

    If you ask us to keep you up to date via email, we may contact you with details about our products and services which we consider may be of interest to you. Where you have given us permission, we may also share your information with those that may be interested in contacting you with information about their products and/or services which may be of interest to you. You may request that we cease contacting you at any time for marketing purposes. To exercise this right please amend your contact preferences on our Website or unsubscribe from our mailing list in the link provided in the email. If you have given us permission to share your information with third parties, please contact such third parties in accordance with their respective privacy terms to stop receiving their communications.

    We will obtain 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 at hello@vidyahealth.com

  • Aggregated Data.

    The service we provide is dependent on the cash management information we collect from you. This means we may use information that we receive from you in providing the services (including information on payment terms, payment behaviour and cash collection) to allow us to make cash flow predictions or assist with providing the services for other clients. From time to time, we may also share anonymized and aggregated information about users of our services and information collected from providing those services, such as by publishing a report or providing information to our business partners on trends in cash management, debtor behaviour and demographic of users.

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.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as an interested customer (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver our services including:
(a) Manage any interactions with you
(b) Keep records of the service we provide to our customers
(a) Identity
(b) Contact
(c) Transaction
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you (a) Identity
(b) Contact
(c) Profile
(d) Recruitment
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and the Websites (a) Identity
(b) Contact
(c) Technical
(d) Usage
(a) Necessary for our legitimate interests (for running our business, network security, to prevent fraud)
(b) Necessary to comply with a legal obligation
To use data analytics to improve our Websites, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
(a) Marketing and Promotional Offers

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 our services 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.

(b) Opting Out

You can ask us or third parties 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 at any time. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us because of a product or service purchase, warranty registration, product/service experience or other transactions.

(c) 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. 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.

(7) Disclosures Of Your Personal Data

We may share your Personal Data with the parties set out below, for the purposes set out in the “Purposes for which we will use your Personal Data” table above:

  • Business partners where doing so is necessary for the performance of our contractual relationship with you
  • Service providers who provide us with IT and system administration services
  • Professional advisers including lawyers, bankers, auditors and insurers
  • HM Revenue & Customs (United Kingdom), regulators and other authorities
  • Any third parties to whom we may choose to sell, transfer or merge parts of our business or assets

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.

(8) International Transfers

Vidya Holdings Ltd does not transfer data outside the European Union. The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (“EEA”). It will also be processed by staff operating inside the EEA who work for us or for one of our third party service providers. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

(9) Data Security

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. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator if we are required to do so.

(10) How Long Will We Use Your Personal Data For?

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. Please contact us using the contact details set out in this Privacy Policy if you have any questions about data retention.

(11) Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. If you wish to exercise any of your legal rights, please contact us using the contact details set out in this Privacy Policy.

You have the right to:

  • Request access to your Personal Data. 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. 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; and (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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.
(a) No Fee Usually Required

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 will notify you if this is the case at the time

(b) Time Limit to Respond

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 several requests. In this case, we will notify you and keep you updated.

(c) Exceptions

It may not be possible for us to delete your Personal Data if we are required to keep it by law or if we hold it in connection with a contract with you. Similarly, access to your Personal Data may be refused if making the information available would reveal Personal Data about another person or if we are legally prevented from such disclosure.