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Privacy Policy

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by reviewing the sections below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? Some of the information may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure.

What are your rights? Depending on where you are located geographically, applicable privacy laws may provide you with certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • Names
  • Email addresses
  • Mailing addresses

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity, such as your name or contact information, but may include device and usage information.

This information may include your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services.
  • Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services.
  • Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information.

  • Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this Privacy Notice.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission or in situations where your permission can be inferred.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
  • For investigations and fraud detection and prevention.
  • For business transactions provided certain conditions are met.
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
  • For identifying injured, ill, or deceased persons and communicating with next of kin.
  • If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse.
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court.
  • If it was produced by an individual in the course of their employment, business, or profession.
  • If the information is publicly available and is specified by the regulations.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Notice.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies, such as web beacons and pixels, to gather information when you interact with our Services.

Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law.

No purpose in this notice will require us keeping your personal information for longer than 2 years.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet can be guaranteed to be 100% secure.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information.

If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.

These rights may include the right to request access and obtain a copy of your personal information, request rectification or erasure, restrict processing, and object to processing in certain circumstances.

We will consider and act upon any request in accordance with applicable data protection laws.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to remove cookies and reject cookies.

If you have questions or comments about your privacy rights, you may email us at privacy@vusigroup.com.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (DNT) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is no industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve months.

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, IP address, email address, and account name. No
B. Personal information Name, contact information, education, employment, employment history, and financial information. No
C. Protected classification characteristics Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data. No
D. Commercial information Transaction information, purchase history, financial details, and payment information. No
E. Biometric information Fingerprints and voiceprints. No
F. Internet or similar network activity Browsing history, search history, online behaviour, interest data, and interactions with websites, applications, systems, and advertisements. No
G. Geolocation data Device location. No
H. Audio, electronic, sensory, or similar information Images and audio, video or call recordings created in connection with our business activities. No
I. Professional or employment-related information Business contact details, job title, work history, and professional qualifications. No
J. Education information Student records and directory information. No
K. Inferences Inferences drawn from collected personal information to create a profile or summary about an individual’s preferences and characteristics. No
L. Sensitive personal information No

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail.

  • Receiving help through our customer support channels.
  • Participation in customer surveys or contests.
  • Facilitation in the delivery of our Services and responding to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in What Information Do We Collect?

How We Use and Share Personal Information

Learn more about how we use your personal information in How Do We Process Your Information?

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider.

We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

  • Right to know whether or not we are processing your personal data.
  • Right to access your personal data.
  • Right to correct inaccuracies in your personal data.
  • Right to request deletion of your personal data.
  • Right to obtain a copy of the personal data you previously shared with us.
  • Right to non-discrimination for exercising your rights.
  • Right to opt out of processing your personal data for targeted advertising, sale of personal data, or profiling.

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at info@vusigroup.com, or by referring to the contact details at the bottom of this document.

We will honour your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@vusigroup.com.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits California residents to request and obtain information about categories of personal information disclosed to third parties for direct marketing purposes.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice.

If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at mike@vusigroup.com, by phone at 07538672559, or by post at:

VUSI GROUP LTD
Data Protection Officer
128 City Road
London EC1V 2NX
United Kingdom

If you are a resident in the United Kingdom, we are the “data controller” of your personal information. We have appointed Mike Ncube to be our representative in the UK.

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information.

You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

To request to review, update, or delete your personal information, please fill out and submit a data subject access request.