Privacy policy

1. Introduction

Your right to privacy is important to us. This Privacy Policy sets out how we treat your personal data. von Lerse Limited, a company registered in England and Wales under company number 09238255) with its registered address at 57 Long Chaulden, Hemel Hempstead, Hertfordshire, HP1 2HXVLL (“VLL”, “we” or “our” or “us”) are committed to safeguarding the privacy of personal data and complying with the European General Data Protection Regulation (2016/679) (“GDPR”) and the UK Data Protection Bill 2017 and any future changes in data protection legislation with which VLL will be required to comply.

VLL is the controller of any personal data collected on the website www.withsto.com and its subdomains (the “Site”). VLL is registered with the Information Commissioner’s Office under number ZA541314. When you register on our Site, we process your personal data such as name, address, contact details, email address and professional qualifications amongst other things. Processing of this data implies collecting, storing, using, disclosing and/or selling your personal data. For the purposes of this Privacy Policy, “user” or “you” means any user of the Site.

This Privacy Policy forms part of VLL’s obligation to be open and fair with all individuals whose personal data we process and to provide details around how we process such personal data and what we do with it.

None of the lists or examples provided in this Privacy Policy is intended to be exhaustive or fully representative of every individual.

2. Scope

The scope of this Privacy Policy covers client personal data in respect of the following:

Ways we use your personal data
Definitions of personal data types
Collecting personal data
Using personal data
Fraud Protection Agencies (FPAs)
Disclosing personal data
Retaining personal data
Securing personal data
Sharing personal data
International Data Transfer
Data Subject Rights
Updates / Amendments
Third Party Websites
Consents ("Opt-in")
Withdrawal of Consent ("Opt-out")
Our Details

3. Ways we use your personal data

We’ll process your personal data:

a) as necessary to perform and fulfil our contracts with you:

to take steps at your request prior to entering into it;
to exercise rights set out in agreements or contracts;
to deliver our products and services;
to update our records;
to make and manage customer payments;
to manage fees and charges due on customer transactions;
to collect and recover money that is owed to us.

b) as necessary to comply with legal obligation, e.g.:

when you exercise your rights under data protection law and make requests;
for compliance and to obey laws and regulations that apply to us;
to verify your identity, make credit, fraud prevention and anti-money laundering checks;
to manage risk for us and our customers;
to detect, investigate, report and seek to prevent financial crime;
to run our business in an efficient and proper way;
to manage how we work with other companies that provide products and services to us and our customers.

c) as necessary for our own legitimate interests, or those or other persons and organisations, e.g.:

for good governance, accounting and managing and auditing our business operations;
to respond to complaints and seek to resolve them;
to run our business in an efficient and proper way;
to develop and manage our brands, products and services;
to manage how we work with other companies that provide products and services to us and our customers;
to monitor emails, calls, other communications and activities with reference to your contract;
to provide advice or guidance about related products and services.

d) based on your consent, e.g.:

to manage our relationship with you;
to develop new ways to meet our customers’ needs and to grow our business;
to develop and carry out marketing activities;
to sell your data to third party marketing providers;
to provide advice or guidance about related products and services.

By registering on our Site, you expressly agree to the use of your personal data as set out in this Privacy Policy. You are free at any time to change your mind and withdraw your consent in whole or in part by contacting us via https://www.withsto.com/contact. The consequence might be that we can’t do certain things for you. To the extent that you have not provided your express consent, we will not use your personal data in the manner described in this paragraph 3(d).

4. Definitions of personal data types

We may use various kinds of personal data, and group them together like this.

Type of Personal data	Description
Contact	Your name, where you live and how to contact you.
Consent	Any permissions, consent or preferences that you give us, including how you would like us to contact you.
Educational	Your academic record, qualifications, skills and achievements.
Professional	Your current and previous professional positions, any promotions and demotions and any other relevant information related to your career.
Contractual	Details about the products and services we provide to you.
Behavioural	Details about how you use our products and services.
Communications	What we learn about you from conversations, emails and letters between you and us.
Open Data and Public Records	Details about you that are in public records and information about you that is openly available on the internet.
Usage Data	Other data about how you use our products and services.
Geo-location	This includes information on where you are located, where you access our Site and where you utilise our Site.

5. Collecting personal data

We may collect and store the following kinds of personal data:

1. Information that you provided to us when applying through our Site, in emails or messages or over the phone.
2. Information contained in or relating to any communication that you send to us through our Site, email, in writing, using instant messaging or over the phone.
3. Information that you provide to us in connection with our marketing communications.
4. Information that you provide to us when using any services we provide or connect you with, or that is generated during the use of those services.
5. Information that you provide as part of electronically signing agreements with us.
6. Information that you provide in performing anti-money laundering, financial and credit checks as well as for fraud and crime prevention and detection purposes.
7. Information related to the security and access of our systems and applications.
8. Information to help us comply with our legal and regulatory obligations, including reporting to and being audited by regulators and external auditors.
9. Information to help us comply with court orders and to exercise and defend our legal rights.
10. Any other personal data that may be sent to us and which we use for legitimate business purposes.
11. Information shared as part of our competitions or promotions.

Before you disclose to us the personal data of another person, you must obtain that person's consent to both the disclosure and the processing of that personal data in accordance with this Privacy Policy.

Data from third parties we work with:

Companies that introduce you to us such as recruitment or training agencies
Educational institutions such as Kaplan Financial Limited or BPP Professional Education Limited
Social networks such as Facebook, LinkedIn or WhatsApp
Various online tuition services

We may need to collect personal data by law, or under the terms of a contract we have with you. By registering on our Site, you consent to the use of your personal data in such manner. If you choose not to give us this personal data, it may delay or prevent us from meeting our obligations or provide certain services.

6. Using personal data

We may use your personal data to:

1. Enable your use of any services that we may provide or connect you with through our Site or third-party websites.
2. Supply you with products and services.
3. Send statements, invoices and payment reminders to you or to collect payments from you.
4. Deal with enquiries and complaints.
5. Perform money laundering, financial and background checks.
6. Use tracing services to obtain onward contact details and collect any unpaid debts for any default by you.
7. Send you marketing communications and sell your data to third party marketing providers where you have consented to such use.
8. Ensure appropriate access to systems and applications.
9. Comply with our legal and regulatory obligations.

7. Fraud Prevention Agencies (FPAs)

We may need to confirm your identity before we provide products or services to you. Once you have registered on our Site, we may also share your personal data as needed to help detect fraud and money-laundering risks. We occasionally use Fraud Prevention Agencies to help us with this.

Both we and fraud prevention agencies can only use your personal data if we have a proper reason to do so. It must be needed for either of us to obey the law, or for a ‘legitimate interest’.

8. Disclosing personal data

We only disclose your personal data in the ways set out in this Privacy Policy or subject to any agreements in place between us. The following circumstances may apply:

As part of a need to know or as part of improving our existing products and services or as part of providing new services.
To third parties who process personal data on our behalf.
To third parties' who process personal data on their own behalf but provide us, or you, with a service on behalf of us.
To third parties with whom information is shared for anti-money laundering checks, credit risk reduction, debt collection and other fraud and crime prevention purposes.
To any regulator, external auditor or applicable body or court where we are required to do so by law or regulation or as part of any investigation.
To any central or local government department and other statutory or public bodies, such as HMRC.
If the law or a public authority says we must share the personal data.
To third party marketing providers who acquire your personal data from us.
If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud or reducing credit risk);
To any other successors in title to our business(es);

By registering on our Site, you expressly consent to us disclosing and supplying your personal data to third parties, including for the purpose of their or any other third party's direct marketing. To the extent that you have not provided your express consent, we will not use your personal data in such a manner.

For the avoidance of doubt, we do not collect or share any sensitive personal data as defined under GDPR.

9. Retaining personal data

The following criteria are used to determine data retention periods for your personal data (whether or not you become a customer):

Retention in case of queries – we will retain your personal data as long as necessary to deal with your queries (e.g. if your potential transaction is unsuccessful);
Retention in case of claims – we will retain your personal data for as long as you might legally bring claims against us; and
Retention in accordance with legal and regulatory requirements – we will retain your personal data after your contract or service with us has come to an end based on legal and regulatory requirements.

10. Securing personal data

We have implemented the necessary and adequate safeguards to prevent unauthorised access, loss, misuse or alteration of your personal data.

Any personal data sent to us, either in writing or email, may be insecure in transit and we cannot guarantee its delivery.

Where you use a password to access any service provided by VLL this must be kept confidential and not disclosed to anyone else.

11. Sharing personal data

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

The table below explains the cookies we use and why:

Category	Type	Purpose
Category 1	Strictly necessary cookies	These are required for the operation of websites. For example, to remember the previous actions so you can navigate back to previous pages. These cookies are essential in order to move around websites and use their features, such as accessing areas of a website. Without these cookies, services you have asked for, like shopping baskets, cannot be provided.
Category 2	Analytical/performance cookies	These cookies collect anonymous information about how visitors use websites. These cookies collect information about how you use a website, for instance which pages you go to most often. These cookies do not collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how websites work and understand what interests our users.
Category 3	Functionality cookies	These are used to recognise users when they return to a website. They remember user choices and enable the personalisation of content. These cookies allow a website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. They may also be used to provide services such as remembering whether you have already responded to a questionnaire. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Category 4	Marketing cookies	These cookies are used to deliver targeted digital marketing. They store user data and behaviour information, which allows advertising services to target audience groups according to variables and this may include personal data.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout

By using the Site without adjusting your web browser to block them, you are consenting to these types of cookies being stored on your device.

12. International Data Transfers

Personal data that we collect, is predominantly stored and processed in the UK, but for specific services may be transferred, stored, processed in other EU member states which have implemented adequate safeguards with regards to your personal data.

13. Log Files and Statistics

VLL may use IP addresses, URLs of requested resources, timestamps and HTTP user agents to administer the system, analyse trends and gather broad demographic information for aggregate use.

In addition to this we may use third party services to monitor your use of our Site, including Google Analytics, a web analytics service provided by Google, Inc ('Google'). This information allows us to track how many visitors we have, how often they visit and where they originated from. It also gives the ability to gather which terms were used when searching for properties.

14. Data Subject Rights

Your rights are as follows (noting that these rights don’t apply in all circumstances):

The right to be informed about our processing of your personal data;
The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed;
The right to object to processing of personal data;
The right to restrict processing of your personal data;
The right to have your personal data erased (the “right to be forgotten”);
The right to request access to your personal data and information about how we process it;
The right to move, copy or transfer your personal data (“data portability”); and
Rights in relation to automated decision making including profiling.

You have the right to complain to the Information Commissioner’s Office. It has enforcement powers and can investigate compliance with data protection law: www.ico.org.uk

For more details on all the above you can contact us via https://www.withsto.com/contact.

15. Updates / Amendments

To remain compliant with any legal and regulatory obligations, or as part of our evolving business practices, we may update this Privacy Policy from time to time by publishing a new version.

16. Third Party Websites

We are not responsible for the practices employed by third-party websites linked to or from our Site nor the information or content contained therein. Often links to other websites are provided solely as reference points to information on topics that may be useful to the users of our Site. Please remember that when you use a link to go from our Site to a third-party website, our Privacy Policy will no longer apply. Your browsing and interaction on any third-party websites, which have a link on our Site, are subject to that website's own Privacy Policy.

17. Consents (“Opt-in”)

By registering on the Site and agreeing to this Privacy Policy, you consent to the use your personal data as set out herein. Where you have not provided your express consent, we will not use your personal data in the manner described in paragraph 3(d) above.

18. Withdrawal of Consent (“Opt-out”)

You have the right, at any time, to ask us not to process your personal data for marketing purposes and any additional services that you have consented to receive.

You can opt-out of receiving any of these services and communications simply by contacting us via https://www.withsto.com/contact.

19. Data Protection Registration

At present we are not required to be registered as a data controller with the UK Information Commissioner's Office.

20. Our Details

You can contact us via https://www.withsto.com/contact.

Privacy policy

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