Privacy Policy

About us

We are Global Venture 100 Limited t/a Qodeo. We are incorporated in England & Wales with UK Companies House registration number 02991369. Our registered office is at UHY Hacker Young, Quadrant House, 4 Thomas More Square, London, E1W 1YW, United Kingdom.

As a “data controller” Qodeo is responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy policy.

Please read this policy carefully

This policy (combined with our website terms of use and cookie policy) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read it carefully. This notice does not form part of any contract to provide services. We may update this notice at any time.

Data Protection Principles

We will comply with data protection law. This says that the personal data we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.

Information we may collect from you

We may collect and process the following data about you:

(a)  Information you give us.  You may give us information about yourself by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site and our services, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site. This information could include your name, address, e-mail address, phone number, personal description, photograph and data or information related to you and your workplace, employer or organization, including career and educational background.

(b)  Information we collect about you.  Each time you visit our site, we may automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full uniform resource locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page; and phone numbers used to call our customer service number.

(c) Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide, if you have consented to this. We are also 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) and may receive information about you from them.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on this, see our cookie policy.

How information is used

We will only use your personal data when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

1. Where we need to perform the contract we are about to enter into or have entered into with you.
2. Where we need to comply with a legal or regulatory obligation.
3. 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.

We may also use your personal information in the following situations, which are likely to be rare:

1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data for any particular data processing activity carried out by us.

We use information held about you in the following ways:

(a) Information you give to us. We will use this information:

• to provide you with the information, products and services that you request from us;
• to provide you with information about other and services we offer that are similar to those that you have already used;
• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. Where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. You can opt-out of receiving such communications at any time by clicking [here];
• to notify you about changes to our services;
• to ensure that content from our site is presented in the most effective manner for you and for your computer;
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
  as part of our efforts to keep our site safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;
• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 women aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in living in a particular local area). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience;
• Analytics and search engine providers that assist us in the improvement and optimisation of our site;
• If we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will form part of the assets transferred;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use, cookie policy, terms and conditions of supply and other agreements; or to protect our rights, property and safety and that of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.

The lawful bases for us processing your personal data in such cases are where we need to perform the contract we are about to enter into or have entered into with you, where we need to comply with a legal or regulatory obligation or where it is in our legitimate interests in operating our business and promoting our services to you.

(b) Information we collect about you. We will use technical information and information about your visit to our site in order to optimise your experience in using our site and to administer and protect our business and site. The lawful basis for processing your personal data in such cases is our legitimate interests in running our business, provision of administration and IT services, network security and to prevent fraud.

(c) Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).

The lawful basis for processing your personal data in such cases is our legitimate interests in running our business, provision of administration and IT services, network security and to prevent fraud.

Disclosure of your information

(a) We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

(b) We may share your information with selected third parties – our technical partners who support our products and services.

(c) We may disclose your personal information to third parties – our technical partners who support our products and services.

Where we store your personal data

(a) The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things: the fulfilment of your order, the processing of your payment details and the provision of support services. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We will ensure there are appropriate measures in place to provide a similar degree of protection for your personal information as that required in the EEA.

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
• Where we are otherwise authorised to transfer your personal data, for example where you have given your explicit consent to the transfer, where it is necessary to performance of a contract between you and us, or where it is for the establishment, exercise or defence of legal claims.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

(b) All information you provide to us is stored on our secure servers which feature SSL technology. Any payment transactions will be encrypted and processed by PCID compliant payment engines/gateways. We do not store your credit or debit card information. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

(c) Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Data retention

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.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

Your rights

Under certain circumstances, by law you have the right to:

• Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us at [email protected].

No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us at [email protected] or by amending your account settings on our site. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Right to complain to the ICO

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.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

‘Visibility’ & ‘Share’ settings

Once you have registered as a user on our site, other users will be able to see the data that we or you post online. You may change the visibility settings for this data by restricting access to some or all users, or by permitting full or near-full visibility to our users. We will use our best endeavours to ensure that your visibility settings reflect accurately on our site. However, we cannot guarantee that this will always be the case, as our site is not completely error-free.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Changes to the policy

We may change this policy from time to time as we add new services or features or in response to changes in the law or our commercial arrangements. Any changes to this policy will be posted on this site.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]