Privacy Notice Of Vanilla Circus Ltd. (‘We’, ‘Our’, Or ‘Us’).
Our registered office is at Thornton House, Thornton Road, London SW19 4NG.
This notice describes how we collect, store, transfer and use personal data. It tells you about your privacy rights and how the law protects you.
In the context of the law and this notice, personal data identifies you as an individual or could be used to identify you if combined with other information. Acting on personal data is referred to as ‘processing’.
This notice applies to personal data collected through our website and social media platforms.
Except as set out below, we do not share, sell, or disclose any information collected through our website to a third party.
Personal data we process
- How we obtain personal data
The information we process about you includes information:
- you have directly provided to us
- that we gather from third-party databases and service providers
- as a result of monitoring how you use our website or our services
- Types of personal data we collect directly
When you use our website, our services or buy from us, for example, when you create an account on our website, we ask you to provide personal data. This can be categorised into the following groups:
- Personal identifiers, such as your first and last names, your title and your date of birth
- contact information, such as your email address, your telephone number and your postal address, for billing, delivery and communication
- account information, including your username and password
- payment information, such as a debit or credit card number and expiry date and bank account details
- records of communication between us, including messages sent through our website, email messages and telephone conversations
- marketing preferences that tell us what types of marketing you would like to receive
- Types of personal data we collect from third parties
We confirm some of the information you provide using data from other sources. We also add to the information we hold about you, sometimes to remove the need for you to provide it to us and sometimes to be able to assess the quality of the services you offer.
The additional information we collect can be categorised as follows:
- data that confirms your identity
- business information, including your business trading name and address, your company number (if incorporated), and your VAT number (if registered)
- data that confirm your contact information
- reviews and feedback about your business on other websites through which you sell your services
- unsolicited complaints by other users
- Types of personal data we collect from your use of our services
By using our website and our services, we process the following:
- your username and password and other information used to access our website and our services
- information you contribute to our community, including reviews
- your replies to polls and surveys
- technical information about the hardware and the software you use to access our website and use our services, including your Internet Protocol (IP) address, your browser type and version and your device’s operating system
- usage information, including the frequency you use our services, the pages of our website that you visit, whether you receive messages from us and whether you reply to those messages
- transaction information that includes the details of the products and services you have bought from us and payments made to us for those services
- your preferences to receive marketing from us, how you wish to communicate with us, and responses and actions about your use of our services.
- Our use of aggregated information
VC may aggregate anonymous information, such as statistical or demographic data; Anonymous Information is that which does not identify you as an individual. Aggregated information may be derived from your data but is not considered in law because it does not reveal your identity.
For example, we may aggregate usage information to assess whether a feature of our website is useful.
However, suppose we combine or connect aggregated information with your data so that it can identify you in any way. In that case, we treat the combined information as personal data, which will be used following this privacy notice.
- Special personal data
Particular personal data is about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.
We do not collect any particular personal data about you.
- If you do not provide personal data, we need
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 that contract.
In that case, we may have to stop providing a service to you. If so, we will notify you of this at that time.
The basis on which we process information about you
The law requires us to determine under which of six defined bases we process different categories of your data and notify you of each category’s basis.
If the basis on which we process your data is no longer relevant, we shall immediately stop processing your data.
If the basis changes, then if required by law, we shall notify you of the difference and any new basis under which we have determined that we can continue processing your information.
- Information we process because we have a contractual obligation to you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.
We must process the information you give us to carry out our obligations under that contract. Some of this information may be personal data.
We may use it to:
- verify your identity for security purposes when you use our services
- sell products to you
- provide you with our services
- provide you with suggestions and advice on products, services and how to obtain the most from using our website
We process this information on the basis there is a contract between us or that you have requested; we use the information before we enter into a legal contract.
We shall continue to process this information until the contract between us ends or is terminated by either party under the termsagreement.
- Information we process with your consent.
Through specific actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and services, you provide your consent to us to process information that may be personal data.
Wherever possible, we aim to obtain your explicit consent to process this information; for example, we ask you to agree to our use of non-essential cookies when you access our website.
If you have given us explicit permission to do so, we may, from time to time, pass your name and contact information to selected associates whom we consider may provide services or products you would find helpful.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You may withdraw your consent at any time by instructing us at email@example.com. However, if you do so, you may not be able to use our website or services further.
We aim to obtain and keep your consent to process your information. However, while we consider your support in deciding whether to process your data, the withdrawal of your consent does not necessarily prevent us from continuing to process it. The law may allow us to continue to process your data, provided that there is another basis on which we may do so. For example, we may have a legal obligation to do so.
- Information we process for legitimate interests
We may process the information on the basis there is a legitimate interest, either to you or to us, in doing so.
When we process your information on this basis, do after having given careful consideration to the following:
- whether the same objective could be achieved through other means
- whether processing (or not processing) might cause you harm
- whether you would expect us to process your data and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis for:
- improving our services
- record-keeping for the proper and necessary administration of our organisational or business
- responding to unsolicited communication from you to which we believe you would expect a response
- preventing fraudulent use of our services
- exercising our legal rights, including detecting and preventing fraud and protecting our intellectual property
- insuring against or obtaining professional advice that is required to manage organisational or business risk
- protecting your interests where we believe we must do so
- Information we process because we have a legal obligation
Sometimes, we must process your data to comply with a statutory obligation.
For example, we may be required to give information to legal authorities if they so request or have the proper authorisation, such as a search warrant or court order.
This may include your data.
How and when we process your data
- Your data is not shared
We do not share or disclose any information collected through our website to a third party.
- Information you provide
Our website allows you to post information with a view of that information being read, copied, downloaded, or used by others.
For example, when you leave a review or post a message on our website, we reasonably assume that you consent for the message to be seen by others. Therefore, we may include your username with your message, and your letter may contain personal data.
Other examples include:
- tagging an image
- clicking on an icon next to another visitor’s message to convey your agreement, disagreement or thanks
In posting personal data, it is up to you to satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except to allow it to be displayed or shared.
We store it and reserve the right to use it in the future in any way we decide.
We provide you with a public profile page, the information on which may be indexed by search engines or used by third parties. The information you provide on that profile page may be available to the public.
Once your information enters the public domain, we have no control over what any individual third party may do with it. Therefore, we accept no responsibility for their actions at any time.
If your request is reasonable, and there is no legal basis for us to retain it, then at our discretion, we may agree to your request to delete the personal data you posted. You can request by contacting us at an email address or webpage.
- Job application and employment
If you send us information in connection with a job application, we may keep it for up to three years if we decide to contact you later.
If we employ you, we occasionally collect information about you and your work throughout your employment. This information will be used only for purposes directly relevant to your job. After your appointment has ended, we will keep your file for six years before destroying or deleting it.
- Information obtained from third parties
Although we do not disclose your data to any third party (except as set out in this notice), we sometimes receive data that is indirectly made up of your data from third parties whose services we use.
No such information is personally identifiable to you.
- Third-party advertising on our website
Third parties may advertise on our website. In doing so, those parties, their agents or other companies working for them may use technology that automatically collects information about you when their advertisement is displayed on our website.
We do not have control over these technologies or the data these parties obtain. Accordingly, this privacy notice does not cover the information practices of these third parties.
- Disputes between users
In case of a dispute between you and another user, provided that you consent, we may share your primary personal data, business information and contact information with the other user.
At our discretion, we may share other information to resolve the dispute through litigation or alternative dispute resolution methods.
- Service providers and business partners
We may share your data with businesses that provide services to us or business partners.
- We may pass your payment information to our payment service provider to take payments from you
- we may use fraud prevention agencies and credit reference agencies to verify your identity, and we may pass your information to those agencies if we strongly suspect fraud on our website
- we may pass your contact information to advertising agencies to use to promote our services to you
- Referral partners
This is information you give us in your capacity as an affiliate of us or as a referral partner.
It allows us to recognise visitors you have referred to us and credit you the commission due for such referrals. It also includes information enabling us to transfer the commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the information and the terms of our relationship.
We expect any affiliate or partner to agree to reciprocate this policy.
Use of Information we collect through automated systems
Cookies are small text files placed on your computer’s hard drive by your web browser when you visit a website that uses them. They allow information gathered on one web page to be stored until it is needed for use at a later date.
They are commonly used to provide you with a personalised experience while you browse a website, for example, allowing your preferences to be remembered.
They can also provide core functionality such as security, network management, and accessibility; record how you interact with the website so that the owner can understand how to improve the experience of other visitors; and serve you advertisements relevant to your browsing history.
Some cookies may last for a defined period, such as one visit (known as a session), one day or until you close your browser. Others stay indefinitely until you delete them.
Your web browser should allow you to delete any cookie you choose. It should also allow you to prevent or limit their use. Your web browser may support a plug-in or add-on that helps you manage which cookies you wish to allow to operate.
The law requires you to give explicit consent for using any cookies that are not strictly necessary for the operation of a website.
- to track how you use our website
- to record whether you have seen specific messages we display on our website
- to keep you signed in to our website
- to record your answers to surveys and questionnaires on our site while you complete them
- to record the conversation thread during a live chat with our support team
- Personal identifiers from your browsing activity
Requests by your web browser to our servers for web pages and other content on our website are recorded.
We record your geographical location, Internet service provider, and IP address. We also record information about the software you use to browse our websites, such as the type of computer or device and the screen resolution.
We use this information in the aggregate to assess the popularity of the web pages on our website and how we perform in providing content to you.
If combined with other information we know about you from previous visits, the data could be used to identify you personally, even if you are not signed in to our website.
Re-marketing involves placing a ‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an ‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to serve you relevant adverts for our services when you visit some other website.
The benefit of re-marketing technology is that we can provide you with more valuable and relevant adverts and not repeatedly show you ones you may have already seen.
We may use third-party advertising services to provide us with re-marketing services from time to time. If you have consented to our use of such tracking technologies, you may see advertisements for our products and services on other websites.
We do not provide your data to advertisers or third-party re-marketing service providers; however, if you are already a member of a website whose affiliated business offers such services, that related company may learn of your preferences concerning your use of our website.
- Your rights
The law requires us to tell you about your rights and our obligations to you regarding the processing and controlling of your data.
We do this now by requesting that you read the information at http://www.knowyourprivacyrights.org.
- Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity in your browser and encrypt any data you give us.
Whenever information is transferred between us, you can check that it is done using SSL by looking for a closed padlock symbol or other trust marks in your browser’s URL bar or toolbar.
- Delivery of services using third-party communication software
With your consent, we may communicate using software provided by a third party, such as Facebook (WhatsApp), Apple (Facetime), Microsoft (Skype) or Zoom Video Communications (Zoom).
Such methods of communication should secure your data using encryption and other technologies. In addition, such software providers should comply with all applicable privacy laws, rules, and regulations, including the GDPR.
Please tell us if you have any concerns about using a particular software for communication. Control over your information.
The personal data we hold about you must be accurate and current. Please inform us if your information changes.
At any time, you may request that we provide you with the personal data we hold about you.
You may review or update personally identifiable information we hold about you at any time by signing in to your account on our website.
To obtain a copy of any information not provided on our website, you should contact us to make that request.
When we receive any request to access, edit or delete personal data, we first take reasonable steps to verify your identity before granting you access or taking action. This is important to safeguard your information.
Please be aware that we are not obliged by law to provide you with all personal data we hold about you and that if we provide you with information, the law allows us to charge for such provision if doing so incurs costs for us. After receiving your request, we will tell you when we expect to provide you with the information and whether we require any fee for providing it to you.
If you wish us to remove personally identifiable information from our website, you should contact us to make your request.
This may limit the service we can provide to you.
We remind you that we are not obliged by law to delete or stop processing your data simply because you do not consent to us doing so. While having your consent is an essential consideration as to whether to process it, we may do so if there is another legitimate basis on which we may process it.
- Communicating with us
When you contact us, whether by telephone, through our website, or by email, we collect the data you gave us to reply with the information you need.
We record your request and our reply to increase the efficiency of our business/organisation.
We do not keep any personally identifiable information associated with your messages, such as your name or email address.
We may keep personally identifiable information associated with your message, such as your name and email address, to track our communications with you and provide high-quality service.
You can find further information about our complaint handling procedure at the webpage URL
When we receive a complaint, we record the information you gave us based on consent. Then, we use that information to resolve your complaint.
We aim to investigate all complaints relating to user-generated content. However, we may not do so as soon as a complaint is made. If we feel it is justified or believe the law requires us to do so, we shall remove the content, while the complaint may not result in the removal. Ultimately, we have to judge whose right will be obstructed: yours or that of the person who posted the content that offends you.
If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.
If your complaint reasonably requires us to notify another person, we may give that person some of the information in your complaint. We do this as infrequently as possible, but it is a matter of our sole discretion whether we give information and, if we do, what that information is.
We may also compile statistics showing information obtained from this source to assess the level of service we provide, but not in a way that could identify you or any other person.
If a dispute is not settled, we hope you will agree to attempt to resolve it by engaging in good faith with us in mediation or arbitration.
If you are dissatisfied with how we process your data, you can complain to the Information Commissioner’s Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/. We would, however, appreciate the opportunity to talk to you about your concern before you approach the ICO.
- Retention period
Except as otherwise mentioned in this privacy notice, we keep your data only for as long as required by us:
- to provide you with the services you have requested
- to comply with other laws, including for the period demanded by our tax authorities
- to support a claim or defence in court
- Compliance with the law
We shall update this privacy notice from time to time as necessary.