Privacy Policy

Privacy Notice

 

Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information.

 

It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

 

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Key Terms:

 

It would be helpful to start by explaining some key terms used in this policy:

We, us, our Vibrant Talent Development Limited, company registered in Northern Ireland with a company number NI632704 having its registered address at 42 Magherana Park, Waringstown, Craigavon, County Armagh, Northern Ireland, BT66 7QF
Contact person Craig Thompson
General Data Protection Regulation
  1. General Data Protection Regulation, Regulation (EU) 2016/679
    the Data Protection Act 2018;
  2. any laws which implement any such laws; and
  3. any laws that replace, extend, re-enact, consolidate or amend any of the foregoing
Personal information Any information relating to an identified or identifiable individual
Special category personal information -Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
-Genetic and biometric data
-Data concerning health, sex life or sexual orientation

Personal information we collect about you

 

We may collect and use the following personal information about you:

  • your name and contact information, including email address and telephone number and company details
  • Information to enable us to check and verify your identity, e.g. your date of birth
  • location data, if you choose to give this to us
  • your billing information, transaction and payment card information
  • your professional online presence, e.g. LinkedIn or Twitter profile
  • your contact history, purchase history and saved items
  • information from accounts you link to us, e.g. Facebook or Twitter
  • information to enable us to undertake credit or other financial checks on you, e.g. when you purchase Mooqi products
  • Information about how you use our website, IT, communication and other systems
  • your responses to surveys, competitions and promotions

 

This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.

How your personal information is collected

 

We collect most of this personal information directly from you—in person, by telephone, text or email, via our website and Mooqi app. However, we may also collect information:

  • from publicly accessible sources, e.g. Companies House or HM Land Registry;
  • directly from a third party, e.g.:
    • credit reference agencies;
    • customer due diligence providers.
  • from cookies on our website—for more information on our use of cookies, please see our cookie policy

How and why we use your personal information

 

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

 

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for Our reasons
To provide products and/or services to you – For the performance of our contract with you or to take steps at your request before entering into a contract
– To enable you to gain access to our Mooqi app as part of the performance of our contract
To prevent and detect fraud that may involve you or organisation you work for For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you
– Conducting checks to identify our customers and verify their identity
– Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator
To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering the use of Mooqi app For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information – For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information
– To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems – For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you
– To comply with our legal and regulatory obligations
Updating and enhancing customer records – For the performance of our contract with you or to take steps at your request before entering into a contract
– To comply with our legal and regulatory obligations
– For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns To comply with our legal and regulatory obligations
Marketing our services to:
—existing and former customers;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
Credit reference checks via external credit reference agencies For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts – For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards
– To comply with our legal and regulatory obligations

The above table does not apply to special category personal information.

 

We would never ask you to provide any special category personal information. However, as part of the function of the Mooqi app, users will be encouraged to enter their current moods against a pre-defined set of values which do not contain special category personal information but users will be able to add notes to these submissions, which may or may not contain information pertaining to the special category personal information. Anonymous reports of these mood factors will be viewable by team managers and administrators of the Mooqi app. No user will have access to view individual’s moods.

 

We will only process special category personal information with your explicit consent

Promotional communications

 

Vibrant Talent Development will not issue direct marketing to users of the app.

 

There may be maintenance updates about the status of the Mooqi app, insights we think you might be interested in or feedback we would like to request from you about your experience of using the service and what we could do to make it better for you. Communication such as this may be sent via by email, text message, telephone or post.

 

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

 

We will always treat your personal information with the utmost respect and never share it with other organisations for marketing purposes.

 

You have the right to opt out of receiving promotional communications at any time by contacting us at info@vibranttalent.co.uk.

 

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

 

We routinely share personal information with:

 

  • our data storage supplier: Amazon AWS hosted in the Republic of Ireland
  • third parties we use to help deliver our products and/or services to you, e.g. payment service providers, technical services providers, such as web designers and developers;
  • other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
  • third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
  • our banks;

 

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to the audit of our accounts.

 

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

 

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal information is held

 

Information may be held at our offices and third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

 

Some of these third parties may be based within the European Economic Area but has an international dimension to their business operation. For instance, all data is securely stored on an Amazon AWS which may operate data storage facilities in various locations around the globe. For more information on Amazon’s privacy policy, we recommend that you visit https://aws.amazon.com/privacy/

How long your personal information will be kept

 

We will hold your personal information on our system for the longest of the following periods: (a) up to two years; (b) as long as the law requires; (c) the end of any period of legal action or investigation.

 

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

 

We respect your right to the personal information we hold, therefore if you wish to modify or delete the information that we hold, you can contact us via info@vibranttalent.co.uk. Vibrant Talent Development may preserve copies when required to do so by law.

Your rights

 

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal information (the right of access)
Rectification The right to require us to correct any mistakes in your personal information
To be forgotten The right to require us to delete your personal information—in certain situations
Restriction of processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email info@vibranttalent.co.uk.

 

We provide a copy of your personal information free of charge. However, we may charge a reasonable fee to cover our administrative costs under certain circumstances.

 

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

 

If you would like to exercise any of those rights, please:

 

  • complete a data subject request form—available on request; or
  • email, call or write to us—see below: ‘How to contact us’; and
  • let us have enough information to identify you (e.g. your full name, address and company details);
  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

 

let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

 

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

 

We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

 

We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

 

This privacy notice was published on 14 November 2019.
We may change this privacy notice from time to time—when we do we will inform you via our website.

How to contact us

 

Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

FAO: Craig Thompson
Vibrant Talent Development Limited
42 Magherana Park,
Waringstown, Craigavon,
County Armagh, Northern Ireland, BT66 7QF

Email: info@vibranttalent.co.uk

Tel: +44 7982 728210