You should read this policy in full, but here are the key points:
The personal information we collect about you falls into two main categories – information you give us (such as your email address or your date of birth) and information we collect from your use of our apps or from third parties (such as which destinations you visit or your IP address).
We need to collect, store and process this information so we can provide a safe, reliable and legal service, and to understand how vTime XR is used so we can make it better. Broadly, the categories of data we collect and store are for:
We use your information for two reasons. Firstly, to allow us to provide a safe, reliable and legal service and to understand how vTime XR is used. This is part of your contract with us when you accept our terms and conditions and if you do not agree to this then you will not be able to and should not try to access our services.
The other use of your data, provided you give us specific consent, is for marketing purposes such as newsletters or competitions. You may withdraw this consent at any time and still continue to use our services, subject to this privacy notice and our terms and conditions.
We never sell your information to third parties. However, like most other internet based services, we use third party service providers (such as Amazon Web Services and Google Analytics) to either host our services or provide additional functionality to our services or marketing.
vTime XR is a global service, so your information may be stored and processed at times on servers outside of the European Union, typically in the USA. The data protection and other laws of the United States and other countries might not be as comprehensive as those in the European Union, but please be assured that we take steps to protect your privacy.
You can ask us at any time to disclose to you or correct what data we hold on you by emailing data@vTime.net, or you can download your data here. Also, you can ask us to delete your data, but once deleted your account will be deactivated and you will not be able to access our services. If you delete your own account, your data will automatically be deleted.
If you have given consent to receive marketing, or for us to use your data for marketing purposes, you may withdraw that consent at any time by using the Update Preferences or Unsubscribe link at the bottom of any email we send you, or here. You will continue to have access to our services subject to this privacy notice and our terms and conditions.
The minimum age for using vTime XR is 16.
Our apps and services are not intended for children (anyone under 16 years of age) and we do not knowingly collect data relating to children.
Our full details are:
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.
This version was last updated on March 12th, 2019 and historic versions can be obtained by contacting us.
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.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
We do not collect any Special Categories of Personal Data about you (this includes details 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). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you (such as our terms and conditions) and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you the vTime services through the apps). In this case, we may have to cancel the services you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
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:
The types of lawful basis that we will rely on to process your personal data are set out in the table below.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which 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 for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new user of our apps and services
Performance of a contract with you
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) 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 enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our apps, services and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant apps, services or website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(b) Performance of a contract with you
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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 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 company outside the vTime group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by adjusting your marketing preferences or by following the opt-out links on any marketing message sent to you, by following this link, 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 as a result of using our apps or services.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules and our terms and conditions or where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 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, unless you have agreed or consented to them doing so, and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We also incorporate various third party plugins and libraries of software into our apps in order to build the vTime functionality. A full list can be found here. Based upon the the licence agreements and supporting documentation provided by them to us, we believe they do not share any personal data with third parties. However, if you are concerned, you should familiarise yourself with their individual privacy policies.
Many of our external third party service providers or partners are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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 of a breach where we are legally required to do so.
We will only retain 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 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 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 requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise 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.
You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
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.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we >process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contractprocessing your data where it is necessary for the performance of a contract to which you are a party (such as our terms and conditions) or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
INTERNAL THIRD PARTIES
Other companies in the vTime Group acting as joint controllers or processors and who are based in the UK or the US.
EXTERNAL THIRD PARTIES
Service providers acting as processors based in the US who provide IT and system administration services. You should review and familiarise yourself with their individual privacy policies.