Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using / processing your data.
If you need any assistance / clarifications / more details, pls., see below how to contact VCV about privacy. 7. Advertising, marketing and your communications preferences
We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you and tell you about them. This is what we call direct marketing.
We may carry out direct marketing by email, phone, text or post. For example, you might have the newsletter hit your inbox.
On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it's you deciding to sign up to the newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out (but we'd be really sorry to see you go, so please gives us a chance by fine tuning your preferences before really leaving us!). The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.
Of course, there are lots of different ways you'll see advertisements for VCV on other sites, and not all of these are based on using personal data – sometimes we just buy good old-fashioned advertising space in the real world and websites and social media. If you see VCV's advertisements on websites, these may not be directed specifically at you, we might just have bid for the space. But here's some things we may do that may be specifically directed at you:
- emails, for example the newsletter;
- text messages, for example with discount codes;
- promotions by post, such as great money off shipping offers, or from our trusted retail partners; and/or
- phone calls, to tell you something that might be relevant to you and your business.
We also work with partners to try and promote the reach of our advertisements and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media.
Tracking Data, and in particular — cookies, help us to deliver website advertising that we believe is most relevant to you and to potential new customers of VCV.
Cookies can also tell us if you have seen a specific advertisement, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our advertisements and control the number of times people might be shown our advertisements (you know, before we risk become annoying). Cookies also help us understand if you've opened a marketing email because we don't want to send you things you don't read.
If you want more information about Tracking Data, in particular — cookies, see Cookies below.
Almost all the cookies that relate to advertising are part of the third — party online advertising networks. If you'd like to read about how you can control which advertisements you see online, see opt-out programs established by the Digital Advertising Alliance
(United States), the Digital Advertising Alliance of Canada
and the European Interactive Digital Advertising Alliance
. We do not control cookies which are set by advertising networks. 8. Cookies
You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used. Generally, they are clever.
Cookies help our website and apps work better and provide lots of help in the background to make the process of being a VCV user a lot easier. You'd miss a lot of these things if they were gone – like it being easy to log in and move from page to page.
Other cookies collect information about how visitors use our website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how our website works.
There are also cookies that allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features.
There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.
When you use our website, your device or browser may send cookies from the third — parties, for example when using embedded content and social network links. It's important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.
You can see more information about the cookies we use as provided above Google Analytics link and here link to Yandex Metrics
We may share personal data with the following categories` third parties:
- Suppliers and service providers (such as technology service providers such as our hosting provider, payment processing and fraud prevention providers);
- auditors and professional advisers like bankers, lawyers, accountants and insurers;
- our clients seeking to hire individuals- so they will be able to see your resume or CV videos on our website;
- government, regulators and law enforcement.
For example, we share personal data with the following specific third parties:
We also share data with the third — parties connected to advertising, retargeting and analytics. Please see Section 8 Cookies 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. 10. Payment information
VCV uses the third party payment processor to process payments made for services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors — VCV does not see your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page. 11. International transfers
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed, such as encryption, firewalls, password protection, third party audits and other internal restrictions. 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 of a breach where we are legally required to do so. 13. Data retention and minimization
We will only keep 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, or law 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 unauthorized 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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a certain period of time after they stop being customers for tax purposes.
In some circumstances you can ask us to delete your data; see Your legal rights below for further information.
In some circumstances we may anonymize 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. 14. Your legal rights
If the General Data Protection Regulation applies to you because you are a citizen of European Union, you have the rights under data protection laws in relation to your personal data:
- The right of access – that's your right to get to know what personal data we hold about you and how and for what purpose those data are being processed;
- The right to rectification – that's your right to make us to correct your personal data that may be incomplete or inaccurate;
- The right to erasure – that's also known as the 'right to be forgotten' where in certain circumstances you can ask us to delete the personal data we have about you (unless there's an overriding legal reason we need to keep it);
- The right to restrict processing – that's a right for you in certain circumstances to ask us to suspend processing personal data;
- The right to data portability – that's a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
- The right to object – that's a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
- Rights in relation to automated decision making and profiling – that's a right you have for us to be transparent about any profiling we do, or any automated decision making.
These rights are subject to certain rules around when you can exercise them. You can see a lot more information on them, if you are interested, on the UK Information Commissioner's Office website
If you wish to exercise any of the rights set out above, please contact us (see Section 15 How to contact VCV about privacy).
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.
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 may 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.
You 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 (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.
15. How to contact VCV about privacy
If you need help about our services, or this website generally, please contact us email@example.com
16. A little request from VCV to you
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. You can do this by updating your account. Thank you.