Privacy Policy

Last updated: January 30, 2020

INTRODUCTION

 

Welcome to the Vision Hill Group Inc. Privacy Policy.

 

The Company respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

 

  1. THE DATA WE COLLECT ABOUT YOU

 

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

 

  1. HOW WE USE YOUR PERSONAL DATA

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

 

  1. INTERNATIONAL TRANSFERS

 

  1. DATA SECURITY

 

  1. DATA RETENTION

 

  1. YOUR LEGAL RIGHTS

 

  1. GLOSSARY

PURPOSE OF THIS PRIVACY POLICY

 

This privacy policy aims to give you information on how the Company collects and processes your personal data through your use of this website, including any data you may provide through this website when you register on our website or request our products and services.

 

This website is not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

 

CONTROLLER

 

Vision Hill Group Inc. is the controller and responsible for your personal data (collectively referred to as the “Company,” “we”, “us” or “our” in this privacy policy).

 

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

 

CONTACT DETAILS

 

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

 

Full name of legal entity: VISION HILL GROUP INC.

 

Email address: info@visionhill.com

 

Postal address: 79 Madison Ave., New York, NY 10016

 

In addition, you have the right to make a complaint at any time to following government agencies:

 

United Kingdom: Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues at www.ico.org.uk.

 

Germany: Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit, the German supervisory authority for data protection issues at http://www.bfdi.bund.de

 

Italy: Garante per la Protezione Dei Dati Personali, the Italian supervisory authority for data protection issues at https://www.garanteprivacy.it

 

Spain: Agencia Española de Protección de Datos, the Spanish supervisory authority for data protection issues at https://www.aepd.es/

 

France: Commission nationale de l’informatique et des libertés, the French supervisory authority for data protection issues at https://www.cnil.fr/en/home

 

We would, however, appreciate the chance to deal with your concerns before you contact a governmental authority for assistance so please contact us in the first instance.

 

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

 

We keep our privacy policy under regular review. This version was last updated on January 30, 2020.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

 

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

 

  • Direct interactions. You may give us your Identity Data and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications; or
  • give us feedback or contact us.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

  • To contact you to offer our products and services after you register on our site.
  • To provide you with requested products and services.
  • Where we need to perform the contract we are about to enter into 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.

See Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

 

Generally, we do not rely on consent as a legal basis for processing your personal data, but we may do so for certain data uses when appropriate.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

 

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity

(b) Contact

Performance of a contract with you
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(a) Identity

(b) Contact

(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 updated and to study how customers use our products/services)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website conten (a) Identity

(b) Contact

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

CHANGE OF PURPOSE

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

 

  • Our employees and staff.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We are a U.S. headquartered company and store and process your information in the United States. This will involve transferring your data outside the European Economic Area (EEA).

 

We ensure your personal data is protected by requiring our U.S. personnel to follow these rules when processing your personal data. These rules are called “binding corporate rules”.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

 

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 

In some circumstances you can ask us to delete your data: see your legal rights below for further information.