Vitruvia Data and Privacy Policy
Our contact details
Name: Vitruvia Ltd
Address: Office 11, Romney Marsh Business Hub, Mountfield Road, New Romney, Kent TN28 8LH
E-mail: humans@vitruvia.org
If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer
Sally Everist
ICO Registration under the name of Vitruvia Ltd, renewed annually automatically.
Reference: ZA888226
The type of personal information we collect
We currently collect and process the following information:
Personal identifiers: your name and email address
Contact data: organisation name and contact details
billing address, delivery address, email address and phone number
Financial data: bank account and payment card details
Transaction data: this includes details about payments to and from you and the services you have purchased from us
Technical data: on our website, IP (internet protocol address), browser type, version, time zone, settings and location
How do we get the personal information and why do we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
Provision of services you have bought, ordered or enquired about
You wish to stay in touch and for us to keep you up to date with what we are doing
We use the information that you have given us to
Deliver services you have purchased, ordered or enquired about
Introduce you to your coach or delivery provider
To stay in touch and keep you up to date with what we are doing and any updates that could be relevant, appropriate or useful to you
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
Your consent. You are able to remove your consent at any time. You can do this by contacting humans@vitruvia.net
We have a contractual obligation
We have a legal obligation
We have a vital interest
We need it to perform a public task
We have a legitimate interest
Website data protection
This privacy policy gives you information on how we, Vitruvia, collect and process your data through the use of our website. This includes data you may provide through the website when, for example, you make a booking or sign up to a newsletter,
All data submitted when making a booking on our website will be processed in accordance with our website’s data policy (sub-processor) and or our company data policy.
Third-party links websites, plug-ins and applications– Vitruvia are not responsible for the privacy policies of third-party websites linked from the Vitruvia website. We do not control these third-party websites and are not responsible for their privacy statements.
Email data management
All data submitted when making a booking via email will be processed in accordance with, and or our company data policy.
If a booking is made on behalf of a third party you warrant that you have secured their express consent to their data being used for this purpose and have in place all relevant policies and processes to ensure compliance with all relevant legislation.
We hold minimal customer details securely: customer name, purchase type, contact details and engagement dates for accountancy and delivery reporting purposes. We do not sell data to third parties. We do not use data for promotional purposes unless specific permission has been given.
How we use and store your personal information
We most commonly use your personal data to
Perform the contract we are about to or have entered into with you
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
Where we need to comply with a legal obligation
Your information is securely stored in our Google cloud or on our website providers cloud. You can read our website providers User’s Data Processing Addendum here https://www.squarespace.com/dpa/
We keep your name, address, email, phone number and the service we delivered in our system and will retain it as long as reasonably necessary. We will dispose of your information by deleting the information from our cloud service.
Purpose/Activity
The type of data we collect
The lawful basis for processing date including basis of legitimate interest
To register you as a new customer
i) Identity
ii) Contact
Performance of a contract with you
To process and delivery your order including:
Payments, fees and charges
Collect and recover money owed to us
i) Identity
ii) Contact
iii) Financial
iv) Transaction
v) Marketing and Communications
a)Performance of a contract with you
b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
a) Notifying you about change to our terms or privacy policy
b) Asking you for a testimonial
i) Identity
ii) Contact
iii)Profile
iv) 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 up to date and to investigate how customers use and respond to our products/services
To suggest and recommend to you about products or services that maybe of interest to you
i) Identity
ii) Contact
iii) Technical
iv) Usage
v) Profile
vi) Marketing and Communications
Necessary for our legitimate interests to develop our products, services and grow our business
To use data analytics to improve our website, products, customer service, marketing, customer relationships and experiences
i) Technical
ii) Usage
Necessary for our legitimate interests (to be able to define types of customers for our products and services, to keep our website updated and relevant and to develop our business and inform our marketing strategy)
Marketing
We aim to provide you with choices regarding certain personal data uses, in particular in connection with marketing and advertising. Our communications will offer you an opportunity to unsubscribe or you can request we delete your personal data by emailing humans@vitruvia.net
Your data protection rights
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at: humans@vitruvia.net if you wish to make a request.
It is important that the personal data we hold about you is accurate and up to date. Please inform us of any changes to your personal data.
Data retention
We will only store your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. This includes the purposes of satisfying any legal, regulatory, tax, accounting or contractual reporting requirements. We may retain your personal data for longer if we believe there is a prospect of litigation in respect to our relationship with you.
Data Collection
Informed consent is when:
• An Individual clearly understands why their information is needed, who it will be shared with and the possible consequences of them agreeing or refusing the proposed use of the data.
• An Individual gives their consent predicated on the above.
Vitruvia will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.
When collecting data, Vitruvia will ensure that the Individual:
a) Clearly understands why the information is needed
b) Understands what it will be used for and what the consequences are should the Individual decide not to give consent to processing
c) Grants explicit consent, either written or verbal for data to be processed
d) Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
e) Has received sufficient information on why their data is needed and how it will be used.
f) Understands that they have the right to withdraw consent at any time.
Data Storage
Information and records relating to service users will be stored securely and will only be accessible to authorised staff.
Information will be stored for only as long as it is needed or required by statute and will be disposed
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to our data protection manager at: cccconfidential@gmail.com
You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
This privacy policy was originally written in February 2021, it is regularly reviewed.
Last reviewed:
13th January 2022
14th February 2023
21st June 202