Our Privacy Notice

When using the term “personal data” or “personal information” in this Privacy Notice, we mean information (including opinions) that relates to you and from which you could be identified, either directly or in combination with other information which we may have in our possession.

We will comply with data protection law and principles in respect to your personal data, which means that your personal data will be:

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

We collect personal data about you from a variety of sources, as follows:

• The personal data is provided to us by you (e.g. when you enquire for one or more of our services, including additional communications via email, telephone or Skype/Zoom/MS Team etc.).
• The personal data is collected in the normal course of our relationship with you
• The personal data has been made public by you (e.g. contacting CVG Solutions via a social media platform).
• The personal data is collected when you visit our Website or use any features or resources available on or through the Website, some of which may be personal data.
• The personal data may be created by us, such as records of your communications with us or reports.

The following is a summary of the types of personal data we collect:

• Personal and contact details: title, full name, address, telephone numbers, email address.
• Consents: consents, permissions, or preferences that you have specified, such as whether you wish to receive direct marketing promotions, blogs alert and newsletters.

The main purposes for using your personal information are (where applicable):

• to support and progress your enquiry for services provided by CVG Solutions.
• To communicate with you
• to facilitate the delivery of the requested services

We use information held about you in the following ways:

• to assess your enquiry to determine our ability to satisfy such enquiry.
• to contact you to arrange a meeting or to discuss/clarify some elements of your enquiry.
• to communicate with you during the corse of the provision of Services.
• to contact you with communications about direct marketing promotions, blogs alerts or newsletters to which you have subscribed.

Data protection and privacy laws requires us to have a “legal basis” or “lawful ground” to collect and handle your personal information. We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal justification to do this.

The following is a summary of the relevant legal bases for the purposes of the Privacy Notice:

• We need to use your personal information to take steps before entering into a contract with you. For example make necessary check as to the validity of your company and your authority level to enter into a contract.
• To satisfy the terms of the Contract between us.
• Our use is necessary for the complying with our legal obligations;
• Where it is necessary for our legitimate interests (or those of a third party) as a commercial organisation (to the extent that your interests and fundamental rights do not override those interests), such as:
  • to detect and protect against fraud;
  • to make sure we are following our own internal procedures so we can deliver the best services
  • delivering the requested alerts or updates to you;
  • establishing, exercising or defending our legal rights in the event of a claim;

We will only disclose personal information to a third party in very limited circumstances, or where we are permitted to do so by law. The third parties to whom we provide your personal data include:

• Other organisations within the CVG Solutions group of companies, where such disclosure is necessary to provide you with our services or to manage our business.
• Stripe – payment providers to authorise and complete payments.
• routeToWeb Limited – website hosting provider
• MS Office 365 – email provider
• Other CVG Solutions’s third party providers including information technology suppliers and infrastructure support services, law firms and other third party suppliers/partner organisations.
• Government, regulatory and law enforcement bodies where we are required in order:
  1. to comply with our legal obligations;
  2. to exercise our legal rights (e.g. pursue or defend a claim); and
  3. for the prevention, detection and investigation of crime.

We may transfer your personal information to third parties in connection with a reorganisation, restructuring, merger, acquisition, sale or transfer of assets, or changing services suppliers provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.

Less commonly, we may process and share your personal data where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.

CVG Solutions will only share your personal data with our contracted service providers when we have established they have adequate and sufficient data protection controls and security controls in place (please also refer to section 8 below). We also implement contractual obligations on these third parties to ensure they can only use your data to provide services to CVG Solutions for the purposes listed above.  The third parties cannot pass your details onto any other parties unless instructed to by CVG Solutions.

We will take appropriate steps to ensure that transfers of personal data are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we are satisfied that alternative arrangements are in place to protect your privacy rights. To achieve this:

• we ensure transfers with CVG Solutions’ Associates are covered by a data sharing agreement or standard contract clauses, which ever is appropriate, entered into by all Associates of CVG Solutions, which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection.
• we will, when transferring personal data to third parties outside the EEA:
  • put in place adequate safeguards, to ensure that your information is protected;
  • include the standard contractual clauses approved by the European Commission for transferring personal information outside the EEA into our contracts with those third parties; or
  • ensure that the country in which your personal information will be handled has been deemed “adequate” by the Information Commissioner’s Office and/or European Commission.
• we carefully validate any requests for information from law enforcement or regulators before disclosing the information.

We will always co-operate with any regulators as required by law to ensure that we remain transparent about the way we handle your personal information.

In any case, our transfer, storage and handling of your personal information will continue to be governed by this Privacy Notice. If you would like further information about the global handling of your personal information, please contact us at info@cvgsolutions.co.uk.

CVG Solutions takes precautions including administrative, technical and physical measures to safeguard your personal information against loss, theft and misuse, as well as against unauthorised access, modification, disclosure, alteration and destruction. We protect electronic data using a variety of security measures including:

• password access,
• data back-up,
• encryption,
• hard drive encryption
• placing confidentiality requirements on employees and service providers and providing training to ensure that your personal data is handled correctly.
• destroying personal information if it is no longer needed for the purposes it was collected.

CVG Solutions will only retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice and as otherwise needed to comply with applicable law and internal company policies. A copy of our Retention Policy and Schedule is available on request.

You have legal rights in connection with personal information. Under certain circumstances, by law you have the right to:

• Request access to your personal information. 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 retification 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 (also known as the ‘Right to be forgotten’) enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it and we have no legitimate ground for retaining such information. 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.
• Object to processing of your personal information by us or on our behalf in certain situations.
• 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 submit your requests in writing to our DPO via the contact details set out in Section 12 below.

Please note, to ensure security of personal information, we may ask you to verify your identity before proceeding with any such request.

Withdrawing Consent

If you have requested CVG Solutions to contact you regarding business alerts, regulatory updates or about future conferences, you may withdraw your consent to be contacted at any time. You can tell us that you no longer wish to be contacted by:

• Sending us an email to info@cvgsolutions.co.uk

We have appointed one of our Director to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal information, please address to:

info@cvgsolutions.co.uk or call 01775 660506.

You also have the right to contact the Information Commissioner’s Office and file a complaint. (https://ico.org.uk/concerns/). The Information Commissioner’s Office will then investigate your complaint accordingly.

We may amend this Privacy Notice from time to time to keep it up to date with legal requirement and the way we operate our business. This Privacy Notice was last reviewed and updated in August 2021.

You have the right:

• to confirmation about whether we process your personal data or not
• if we do process your personal data, to have access to your data, and certain other information, including the purposes of the processing, the categories of personal data concerned and the recipients of your personal data,

providing you supply us with two forms of authenticated identification, and the rights and freedoms of others are not affected, we will supply you a copy of your personal data.

You have the right:

• to have any inaccurate personal data about you rectified
• taking into account the purposes of processing, to have any incomplete personal data about you completed
• while your data is in the process of being rectified any processes will be restricted.

In some circumstances, you have the right:

• to the erasure of your personal data without undue delay.

Those circumstances include:

• personal data records are no longer necessary in relation to the purposes for which they were collected or processed
• you withdraw consent to consent-based processing
• you object to the processing under certain rules of applicable data protection law
• the processing is for direct marketing purposes
• your personal data has been unlawfully processed.

However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary:

• for exercising the right of freedom of expression and information
• for compliance with a legal obligation
• for the establishment, exercise or defence of legal claims.

In some circumstances, you have the right:

• to restrict the processing of your personal data.

Those circumstances include:

• personal data records are no longer necessary in relation to the purposes for which they were collected or processed
• processing is unlawful but you oppose erasure
• we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and,
• you have objected to processing, pending the verification of that objection.

Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it:

• with your consent
• for the establishment, exercise or defence of legal claims
• for the protection of the rights of another natural or legal person; or for reasons of important public interest.

You have the right to object to us processing your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will stop processing your personal data for this purpose.

To the extent that the legal basis for our processing of your personal data is:

• consent; or
• processing is necessary for the delivery of, or entry into, a contract to which you are party and is carried out by automated means,

you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.

However, this right does not apply where it would adversely affect the rights and freedoms of others.

If you have requested CVG Solutions to contact you regarding business alerts, regulatory updates, or future conferences, you may withdraw your consent to be contacted at any time. You can tell us you longer wish to be contacted by clicking the button below:

You can contact us to exercise any of your data rights as follows:

• Email: unsubscribe@cvgsolutions.co.uk
• Call: 01775 660506
• Write to us at our office address:
  CVG Solutions, Rose Villa, Tydd Road, West Pinchbeck, Spalding PE11 3PZ

We have appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Notice. If you have questions about this Privacy Notice or how we handle your personal data, please contact:

• Email: info@cvgsolutions.co.uk
• Call: 01775 660506
• Write to us at our office address:
  Data Protection Officer, CVG Solutions, Rose Villa, Tydd Road, West Pinchbeck, Spalding PE11 3PZ

You also have the right to contact the Information Commissioner’s Office (ICO) and file a complaint. The Information Commissioner’s Office will then investigate your complaint accordingly. You can see more information at the ICO website: ICO – Your Concerns

We may update this Privacy Notice from time to time to keep it up-to-date with legal requirements and the way we do business. This Privacy Notice was last reviewed and updated in February 2020.

Please regularly check this website page for the latest version of this Privacy Notice.

Our website may include links to, and details of, third party websites. We are not responsible for the privacy policies and practices of third parties.

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