Privacy Policy

Last revised: March 1, 2020

At Vamstar®, we are committed to protecting your privacy and safeguarding your personal information. The purpose of this Privacy Statement is to inform you about the types of Personal Information Vamstar® collects, uses, and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.

Your privacy is one of our priorities. We are proud to demonstrate our commitment to your privacy, by complying with the laws and regulations under applicable privacy laws in the UK – notably, the General Data Protection Regulation and the regulations thereunder (“GDPR”).

From time to time, we may make changes to this Privacy Statement. We treat Personal Information in a manner consistent with this Privacy Statement unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.

  1. WHAT IS PERSONAL INFORMATION?

“Personal Information” is any information that is identifiable with you, as an individual. This information may include but is not limited to your name, title, mailing address, e-mail address, telephone number, and website usage data (as discussed below). Personal Information, however, does not include any information that is solely used to communicate with you in relation to your employment, business, or profession, such as your name, position name or title, work address, work telephone number, or work email address.

  1. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We will only collect your Personal Information by fair and lawful means (for example, when you register for a Vamstar® account or update your Vamstar® profile). We may collect Personal Information from you directly and/or from third parties, only after obtaining your consent, or as otherwise required or permitted by law.

  1. WHERE DO WE STORE YOUR PERSONAL INFORMATION?

All Personal Information entered into Vamstar® is securely stored on one of the largest shared hosting providers in the world on solid-state cloud servers.

  1. HOW DO WE USE YOUR PERSONAL INFORMATION?

We identify the purposes for which we might use your Personal Information at the time we collect such information, all prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):

  • to register or administer any membership account associated with you;
  • to process transactions;
  • to optimize your experience on our website and Vamstar®platform;
  • to respond to inquiries and other requests, and to investigate legal claims;
  • to collect opinions and comments in regard to Vamstar®;
  • to conduct contests and promotions;
  • to perform demographic analysis for planning purposes (but only on an aggregate and anonymous basis);
  • other purposes for which Vamstar®may obtain your consent from time to time; and
  • other uses as may be permitted and/or required by applicable law.

 

  1. TO WHOM DO WE PROVIDE YOUR PERSONAL INFORMATION?

We identify to whom, and for what purposes we disclose your Personal Information, at the time we collect such information from you.

We may transfer your Personal Information to third party service providers with whom we have confidentiality provisions in written agreements, in which they provide services to assist us with the Purposes, such as providing technical support, data storage, processing, or hosting.

We may transfer your Personal Information outside of the UK, to service providers tasked with data processing and storage in connection with the Purposes. However, you should note that to the extent that any Personal Information is out of the country, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country. For written information about our practices regarding service providers outside of the UK, contact our Privacy Officer (see question 16 below).

  1. WHEN AND HOW DO WE OBTAIN YOUR CONSENT?

We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information. You may provide your consent to us verbally, electronically, or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable privacy expectations you might have.

  1. HOW DO WE ENSURE THE PRIVACY OF YOUR PERSONAL INFORMATION WHEN DEALING WITH OUR AFFILIATES AND OTHER THIRD PARTIES?

We ensure that our affiliates and other third parties that are engaged to perform services for us or on our behalf are contractually required to observe the intent of this Privacy Statement and our privacy practices.

  1. HOW LONG WILL WE UTILIZE, DISCLOSE OR RETAIN YOUR PERSONAL INFORMATION?

We will utilize, disclose, or retain your Personal Information for as long as necessary to fulfill the Purposes for which that Personal Information was collected or as permitted or required by law.

  1. HOW CAN YOU REVIEW YOUR PERSONAL INFORMATION THAT WE HAVE COLLECTED, UTILIZED OR DISCLOSED?

Write us and request a copy of the Personal Information we have about you, and we will provide you with any such Personal Information to the extent required by law. We will make such Personal Information available to you in a form that is generally understandable, and will explain any abbreviations or codes.

  1. HOW DO YOU KNOW THAT THE PERSONAL INFORMATION WE HAVE ON YOU IS ACCURATE?

We will ensure that your Personal Information is kept as accurate, complete, and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. We expect you, from time to time, to supply us with written updates to your Personal Information, when required.

  1. WHAT IF THE PERSONAL INFORMATION WE HAVE ON YOU IS INACCURATE?

At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will update those third parties having access to your Personal Information.

  1. HOW FAST WILL WE RESPOND TO YOUR WRITTEN REQUESTS?

We will attempt to respond to each of your written requests no later than 30 days after receipt, but we will let you know if it might take longer. You have the right to make a complaint to the Privacy Commissioner of the UK in respect of this time limit.

  1. ARE THERE ANY COSTS TO YOU FOR REQUESTING INFORMATION ABOUT YOUR PERSONAL INFORMATION OR OUR PRIVACY PRACTICES?

Typically, we do not charge for you to access your own Personal Information in our records; but we will provide you with an estimate, if there is a fee.

  1. HOW DO WE KNOW THAT IT IS REALLY YOU REQUESTING YOUR PERSONAL INFORMATION?

We may request that you provide sufficient identification to permit access to the existence, use, or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.

  1. WHAT SAFEGUARDS HAVE WE IMPLEMENTED TO PROTECT YOUR PERSONAL INFORMATION?

We have implemented physical, organizational, contractual, and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, non-permitted use or modification. The only personnel granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

  1. HOW DO YOU CONTACT US REGARDING ACCESS TO YOUR PERSONAL INFORMATION OR OUR PRIVACY PRACTICES?

All comments, questions, concerns, or complaints regarding your Personal Information or our privacy practices should be forwarded to our Privacy Officer as follows:

Attention Chief Privacy Officer

By email: PrivacyOfficer@vamstar.io