Introduction

VCG Technology Services Limited ("VCG", "we", "us" or "our") respects your privacy and is committed to protecting your personal data. This notice explains what personal data we hold about you, what we do with it, and what rights you have.

It applies whether you gave us your details yourself or we obtained them from somewhere else. It covers people who work at organisations we sell to or market to, contacts at our customers and suppliers, people who visit our website, and people who attend our events.

It does not cover personal data we hold about our own employees and workers, which is explained in a separate notice available from HR. It does not cover job applicants, who are given a separate notice when they apply.

Who we are and how to contact us

VCG Technology Services Limited, company number 04380546, of 1 Signal Point, Bredbury Park Way, Bredbury, Stockport, SK6 2SN, is the controller of your personal data. Our registration number with the Information Commissioner's Office is Z9921056. We are a subsidiary of Vodat Communications Group (VCG) Holding Ltd.

For anything to do with your personal data or this notice, contact our Data Protection Lead at compliance@vcg.group, by telephone on +44 (0)161 406 1820, or by post at the address above. Please use compliance@vcg.group rather than our general enquiries address, so that your request reaches the right team and we can meet the deadlines the law sets us.

The personal data we hold

Personal data means information about an individual from which that person can be identified. It does not include information where the identity has been removed.

What we hold depends on our relationship with you.

If you are a business contact, prospect or customer contact

•     Identity and role information, such as your name, job title, seniority and function.

•     Business contact information, such as your work email address and work telephone number.

•     Employer information, such as the organisation you work for and its sector, size and location.

•     Your professional networking profile, where it is publicly available.

•     A record of our dealings with you, such as emails you have opened, clicked or replied to, calls we have had with you including recordings and any transcript or summary, meetings, forms you have submitted, events you have registered for or attended, pages you have viewed on our website once we can identify you, and your marketing preferences.

If you are a contact at a customer or supplier

•     The information above, plus records relating to the contract, orders, support tickets and correspondence.

•     Payment and billing records. These relate to your organisation rather than to you personally, and we do not hold personal bank or payment card details for individual business contacts.

If you visit our website

•     Technical information, such as your IP address, browser type and version, operating system, device information and time zone.

•     Information about how you use the site, such as pages viewed, time spent and how you arrived.

•     Where you have accepted our cookies and we can identify you, that activity is linked to your contact record. This is explained under Cookies and website tracking below.

Sensitive information

We do not seek special category information about you, such as information about your health, your beliefs or your personal life, and we do not seek information about criminal convictions or offences.

There are two exceptions to be open about. If you tell us about a dietary or accessibility requirement so that we can look after you at an event, that may reveal information about your health or your beliefs, and we use it only in connection with that event. And because we record calls, anything you happen to mention during a call will be captured in that recording.

Where we get your information

Directly from you, when you fill in a form on our website, ask for information or a call back, subscribe to our mailing list, register for or attend an event, give us your details at an event, correspond with us, or become a customer or supplier.

Automatically, when you use our website, through cookies and similar technologies, as described under Cookies and website tracking below.

From other organisations, specifically:

•     Business to business contact data providers, currently including Cognism, which supply the work contact details of people whose role suggests our services may be relevant to their organisation.

•     Marketing partners who contact organisations on our behalf and pass on the details of those who express an interest.

•     Organisers of events we sponsor or exhibit at, who may supply delegate details or the details of people who visited our stand.

•     Referrals from customers, partners and contacts.

•     Publicly available sources, such as Companies House and organisations' own websites.

We only take business contact details from these sources, meaning a work email address or a work telephone number. If we have contacted you using a personal email address or personal telephone number, please tell us and we will delete it and ask the provider to correct their records.

If you would like to know where we got your details, ask us and we will tell you.

We also use information about organisations rather than about you personally, such as sector, size, location, technology interests and indications that an organisation is researching topics related to our services. Where that information relates to a company rather than to you as an individual, it is not personal data.

What we use your information for

We only use your personal data where the law allows us to. The table below sets out each purpose and the lawful basis we rely on. Where we rely on legitimate interests, we say what that interest is. We may rely on more than one basis for a given purpose.

 

Purpose	Information used	Lawful basis
To market our services to you by email, including sending research, guidance, event invitations and company news	Identity and role, business contact, employer, engagement and preference information	Your consent, where you have asked to hear from us. Otherwise our legitimate interests in promoting our services to organisations likely to need them
To contact you by telephone to discuss whether we can help your organisation	Identity and role, business contact, employer information	Our legitimate interests in identifying organisations that may need our services
To decide who to contact, about what, and in what order, including scoring how likely a contact is to be interested	Identity and role, employer, engagement information, website activity where we can identify you	Our legitimate interests in directing our effort where it is most likely to be relevant and in avoiding contacting people about things that do not apply to them
To record calls, and where we do so to produce a transcript or summary	Call recordings, transcripts and summaries	Our legitimate interests in keeping an accurate record of our dealings with you, resolving any disagreement about what was agreed, and maintaining the quality of our service
To register you as a customer and to perform our contract, including delivering services, managing payments and recovering money owed	Identity and role, business contact, employer, contract, order and payment information	Performance of our contract with you or with your organisation. Our legitimate interests in recovering debts owed to us
To manage our relationship with you, including notifying you of changes to our terms or this notice, and asking for feedback	Identity and role, business contact, contract and engagement information	Performance of our contract. Compliance with a legal obligation. Our legitimate interests in keeping our records accurate and understanding how our services are used
To provide support and resolve issues	Identity and role, business contact, contract, ticket and correspondence information, call recordings	Performance of our contract. Our legitimate interests in supporting our services
To run our events, including registration, attendance and follow up	Identity and role, business contact, employer, attendance information, and dietary or accessibility requirements where you provide them	Our legitimate interests in running events for customers and prospective customers. Your explicit consent for any dietary or accessibility information, meaning that you choose to give it to us and can ask us to delete it
To run and improve our website, and to understand how it is used	Technical and usage information	Your consent for non essential cookies and similar technologies. Our legitimate interests in maintaining and improving the site
To advertise our services on third party platforms	Technical and usage information collected through advertising cookies. Information about organisations and job roles, which is not personal data	Your consent for advertising cookies. We do not upload your contact details to advertising platforms
To administer and protect our business and systems, including troubleshooting, testing, maintenance, security and fraud prevention	Identity and role, business contact, technical information	Our legitimate interests in running our business securely. Compliance with a legal obligation
To comply with our legal and regulatory obligations, including tax, accounting and responding to lawful requests	Whatever is relevant to the obligation	Compliance with a legal obligation
To handle a request you make about your personal data, or a complaint	Identity and role, business contact, the request and our response	Compliance with a legal obligation
In connection with a sale, merger or reorganisation of our business	Whatever is relevant to the transaction	Our legitimate interests in being able to buy, sell or restructure our business

 

You can ask us for a copy of the assessment we have carried out weighing our legitimate interests against your rights, and we will provide it.

Marketing: how we contact you and how to stop it

There are two ways you might hear from us. Our team may contact you directly by email or telephone, from an individual person's email address or phone number. We also send research, guidance, thought leadership and company news from our central marketing address.

You have the right to object to us using your information for marketing at any time. This right is absolute. If you object we will stop, and we will not ask you to give a reason.

You can object by clicking the unsubscribe or preferences link in any of our marketing emails, by telling whoever calls you, by replying to an email from a member of our team, or by emailing compliance@vcg.group.

Our preferences link lets you choose which kinds of communication you receive, so you can stop one without stopping the other. If you ask us to stop everything, or you ask us in your own words to leave you alone, we will apply that across every channel, including individual emails from members of our team, telephone calls and any other marketing we do, and we will tell our marketing partners not to contact you either.

If you have asked us not to contact you, we will keep a minimal record of your contact details on a suppression list. That record exists only so that we do not contact you again by mistake, and it is not used for anything else.

Scoring and prioritisation

We use software to score how likely a contact is to be interested in our services, based on job role, organisation profile and how you have interacted with us. We use that score to decide who to contact and about what, and in some cases you may be added to a sequence of marketing emails as a result of it.

This affects only what marketing you receive from us and which of our team gets in touch. It does not produce any legal effect for you and does not otherwise significantly affect you, and you can ask us to stop at any time.

Call recording and transcription

We record calls with our teams. We also sometimes use software to produce a written transcript of a call and a short summary, which we keep on your contact record so that we have an accurate note of what was discussed.

Video meetings may also be recorded and transcribed. Where they are, the meeting software tells everyone present at the time.

A summary is produced by software, so it may not always be a perfect account of what was said. If you think a note we hold about you is wrong, tell us and we will correct it.

Cookies and website tracking

Cookies are small files placed on your device. Our cookie banner sorts them into four groups: necessary, preferences, statistics and marketing. Only the necessary group is switched on by default, because the site will not work without it. Nothing in the other three groups is set unless you turn it on. You can accept all, choose individual groups, or decline everything, and you can change or withdraw your choices at any time using the cookie settings link on our website.

Where you have agreed to these cookies, and you have also either clicked a link in one of our emails or submitted a form on our website, we are able to link the pages you go on to view to your contact record. That means we can see which pages you have looked at and when, and we use it to judge which of our services are likely to be relevant to you and to decide what to send you. This applies to pages across our website, not only to pages you reach from an email.

This means that if you have not accepted the statistics or marketing cookies, we cannot link your browsing to your record and we do not. If you have accepted them and would rather we stopped, withdraw your consent through the cookie settings, or contact us and we will stop linking your website activity to your record. If you decline cookies, parts of the website may not work as well, but you will still be able to use it.

Who we share your information with

We share personal data with the following categories of recipient:

•     Providers of the systems we use to run our business, including customer relationship management and marketing, email and telephony, call recording and transcription, events and webinars, website hosting and analytics, and finance and billing. These providers act on our instructions and are not permitted to use your information for their own purposes.

•     Suppliers, subcontractors and partners who help us deliver our services, including field engineering and installation partners, maintenance providers, hardware and software vendors and telecommunications carriers. Where they need your contact details in order to carry out work for your organisation, we share only what is necessary.

•     Marketing partners who contact organisations on our behalf. We give them our suppression list so they do not contact anyone who has asked us to stop.

•     Professional advisers, including lawyers, accountants, auditors, insurers and bankers, who act as independent controllers of the information we give them.

•     HM Revenue and Customs, regulators, law enforcement and other authorities, where we are required or permitted to report or disclose. These bodies act as independent controllers of that information.

•     Our parent company, Vodat Communications Group (VCG) Holding Ltd, where necessary for management reporting and group administration.

•     Our investors and their professional advisers, and the chairman appointed by our investor, where necessary for reporting on the performance of the business, for monitoring their investment, or for due diligence. We do not share personal data with our investors for marketing purposes.

•     A buyer or seller, in connection with a sale, merger or reorganisation of our business.

We keep an internal record of the providers and partners we use and you can ask us who they are. We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.

We advertise on third party platforms, including professional and social networks and search engines. We do this by telling the platform the kinds of organisation and job role we want to reach, for example by naming the companies and job functions we are interested in. We do not upload your contact details to those platforms.

Sending information outside the UK

Some of the providers and partners we use are based outside the United Kingdom, or may access your information from outside the United Kingdom. Where your personal data is transferred outside the UK, we put in place the appropriate safeguards required by UK data protection law so that it remains protected to UK standards.

You can ask us which safeguard applies to a particular provider and we will tell you.

Separately, we sometimes deliver or maintain services at sites outside the United Kingdom for customers based here. Where we do, we may hold the name and work contact details of a contact at that site so that we can carry out the work. We do not market to contacts outside the United Kingdom.

How long we keep your information

We keep your information for as long as we have a reason to, and no longer.

For business contact details held for marketing and sales, that means for as long as you remain someone who might have a requirement for our services and you have not asked us to stop hearing from us. We review this and delete details we no longer need.

For customers and suppliers, we keep records for the duration of the relationship and for as long afterwards as we need them in order to meet our contractual, tax and accounting obligations and to deal with any legal claim.

We keep a record of your marketing preferences, and of any objection you have made, for as long as we need it in order to honour your request.

Call recordings are kept for a limited period. Where we produce a transcript or a summary of a call, it is kept with the record it relates to.

If you want to know how long we will keep a particular kind of information about you, ask us and we will tell you.

If we delete your details because you have not engaged with us, we do not keep a record of you, so if a data provider supplies your details again in future we may contact you again. If that happens, we will tell you where we got them and how to stop. If you have asked us not to contact you, that is different: we keep the minimal suppression record described above, so that your request continues to be honoured.

Keeping your information secure

We have appropriate technical and organisational measures in place to protect your personal data against accidental loss, unauthorised access, alteration or disclosure. Access is limited to those who need it for their work. We have procedures for dealing with any suspected personal data breach, and we will notify you and the Information Commissioner's Office where the law requires us to.

Your rights

You have the following rights in relation to your personal data:

•     To be told what we hold about you and to receive a copy of it.

•     To have inaccurate information corrected, and incomplete information completed.

•     To have your information deleted, where there is no good reason for us to keep it.

•     To object to our use of your information for marketing. This right is absolute and we will always honour it.

•     To object to our use of your information where we rely on legitimate interests for something else.

•     To ask us to restrict how we use your information while a question about it is resolved.

•     To receive information you have given us in a portable format, in some circumstances.

•     To withdraw consent, where we rely on it.

To exercise any of these rights, contact compliance@vcg.group. We will respond within one month. If your request is complex we may need longer, in which case we will tell you within the first month and explain why.

There is no charge. We may ask you for enough information to satisfy ourselves who you are, but only where we genuinely have doubts, and we will ask for the least we can. Usually confirming details we already hold is enough, and we will not insist on formal identity documents unless the circumstances make it necessary.

Complaints

If you are unhappy with how we have handled your personal data, please tell us first at compliance@vcg.group so that we have the chance to put it right. You also have the right to complain to the Information Commissioner's Office, the UK regulator for data protection, at ico.org.uk or on 0303 123 1113. Complaining to us first does not affect that right.

Changes to this notice

We may update this notice from time to time, for example if the law changes or we start doing something new with personal data. The date at the top shows when it was last updated. Where a change materially affects how we use your information, we will bring it to your attention rather than relying on you noticing.