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:
3. Ways we use your personal data
We’ll process your personal data:
a) as necessary to perform and fulfil our contracts with you:
b) as necessary to comply with legal obligation, e.g.:
c) as necessary for our own legitimate interests, or those or other persons and organisations, e.g.:
d) based on your consent, e.g.:
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:
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:
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:
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:
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):
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. |
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):
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.