1. Introduction

Vyspa Limited, company number 07263178 is strongly committed to respecting and protecting your privacy. Please carefully read the following Privacy Policy. In order to ensure your privacy, Personal Information (as defined below) Vyspa collects from you as a customer or potential customer or, visitor to its website ("Customer(s)" and/or "you") located at www.vyspa.com ("Site"), is used only in the manner and for the purposes described in this Privacy Policy.

"Personal Information" includes any information which can identify an individual, presented in any form, such as: age, name, address (incl. email address), ID numbers, income, credit references and records, ethnic origin, and evaluations.

This Privacy Policy expresses our approach to complying with the Data Protection laws that apply in the UK, and applies to the collection of your Personal Information via the Site.

You must not register with Vyspa or sign up to any Vyspa service available via this Site if you do not accept this Privacy Policy and the Vyspa Terms & Conditions.

2. Your Personal Information and the purposes for which information is used

As a general principle, Vyspa will identify the purposes for which personal information is collected at or before the time the information is collected.

What information will Vyspa collect? When registering with Vyspa you must provide Vyspa with the following personal information:

  • your full name;
  • your address;
  • your email address;
  • current phone number;
  • credit card details;

Vyspa may also collect Personal Information from such third parties as credit bureaus, employers or personal references or other third parties that represent that they have the right to disclose the information.

Purposes: This information and any other information you provide to Vyspa via the Site, email or telephone is required in order to provide you with Vyspa’s services and the relevant equipment required to use Vyspa’s services. Also to verify your credit status with third party credit agencies and to inform you of any new offers and services which may be of interest to you.

Vyspa collects Personal Information only for the purposes set out in this Privacy Policy, including to provide service(s) and/or products to its Customers:

  • to maintain commercial relations and to communicate with its Customers (which will include, but not be limited to: billing, collection, support, advertising, promotion, account and credit card verification);

  • to evaluate Customers' financial status and eligibility for credit;

  • to identify Customer needs and/or preferences;

  • to meet legal and regulatory requirements;

  • to administer and manage its business operations; and as otherwise required or permitted by law.

    3. Limiting use, disclosure and retention

    Sharing and use of Personal Information: The over-riding principles Vyspa apply are these:

    a)Vyspa, and (where relevant) our credit card processing agents or other third parties we share your information with, will not supply your personal data to a third party for commercial exploitation - thus, you can rest assured that we will not sell the lists of our Customers' email addresses to a third party; and

    b)The only circumstances in which we will provide any of your personal data to a third party for non-commercial purposes are those contained in this Privacy Policy.

    Credit card information: There has been a lot of publicity about credit card security on the internet so Vyspa has decided to operate a secure server, to process credit card payments. Vyspa encrypts Customers' credit or debit card information and authorise payment directly. Vyspa may transfer to, process and hold your credit card information in countries either within or outside the European Economic Area in connection with performing Vyspa's duties.

    Changes in Vyspa's business. Personal Information may also be disclosed in connection with a sale, transfer or reorganisation of one or more of Vyspa's businesses, in which case Vyspa will require that any Personal Information will continue to be treated in accordance with this Privacy Policy or as otherwise permitted by law.

    Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of you, the individual or as otherwise required or permitted by law. Personal Information will be retained only as long as necessary for the fulfilment of those identified purposes or as otherwise required or permitted by law.

    Vyspa may disclose a Customer's Personal Information to:

  • another company for the provision of its services to that Customer;

  • a person involved in the development, promotion, marketing or enhancement of Vyspa services;

  • a credit checking or collections agency;

  • emergency services in an emergency situation;

  • third party affiliates for administrative purposes (for example, Customer billing, support, marketing, etc.); and

  • any other third party, upon receiving the consent of the Customer or as required by law.

    Such disclosures may in some cases be to recipients outside of UK and European Economic Area.

    Vyspa will retain Personal Information that has been used to make a decision about an individual long enough to allow the individual access to the information after the decision has been made, and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law.

    When Personal Information that previously has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless otherwise permitted by applicable law, Vyspa will obtain the consent of the individual before information is used for that new purpose.

    Occasionally, Vyspa will communicate to you special bonus and new product offers that we think may be of value to you. Vyspa may retain third parties to assist it in marketing such new or additional Vyspa products and services to our Customers (and for such purpose may share Personal Information with such third parties) but will not otherwise disclose or make available any Personal Information to any third parties seeking to market their products to Vyspa's Customers.

    All Vyspa Customers have the right to choose not to participate in direct marketing of new products and services from Vyspa. If you wish to opt-out of receiving targeted communications from Vyspa in electronic, printed or verbal format (other than information included with your monthly bills), simply inform us in writing at Vyspa: c/o Privacy Officer, privacyofficer@vyspa.co.uk

    The Site may provide hyperlinks, which are highlighted words or pictures within a hypertext document that may, when clicked, take you to a third party website not controlled by Vyspa. Such hyperlinked third party websites may collect and disclose information in a different way to this Site. Vyspa is not responsible for the collection, use, or disclosure of information collected through these third party web sites, and Vyspa expressly disclaims any and all liability related to such collection, use, or disclosure.

    4. Consent to transfer of Personal Information Overseas

    Place of processing: The Personal Information held by Vyspa is stored on and processed on computers situated in the United Kingdom.

    The knowledge and consent of you, the individual is normally required for the transfer of Personal Information to a destination outside the EEA, subject to certain exceptions. In certain circumstances, Personal Information can be transferred to a destination outside the EEA without the knowledge and consent of the individual.

    Personal Information is transferred abroad for the purpose of performing contractual obligations owed by Vyspa to you.

    Consent: Where required, Vyspa will generally seek consent for the use or transfer the information overseas at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Vyspa wants to use information for a purpose not previously identified).

    You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Vyspa will inform you of the implications of such withdrawal. In order to withdraw consent, you must provide notice to Vyspa in writing.

    5. Cookies Policy

    The Site uses a feature of Internet web browsers called a cookie, which is a file that is sent to your browser from the Site's computers and stored on your computer's hard drive. A cookie assigns a unique identification code to your computer.

    Cookies are used to track and maintain continuity of web sessions such as the subscription process or your viewing of your call details. They also help us track visitors, conduct research, allow you to back click to earlier registration pages viewed by you and improve our content and services.

    Vyspa’s cookies do not collect Personal Information other than the IP address from which you are accessing the Site which may be considered Personal Information. Vyspa only collects Personal Information if you knowingly and willingly provide such information.

    On this Site, the following types of cookie are used:

  • Session cookies: these cookies are temporary and will be removed from your computer when you leave the Site.

  • Persistent cookies: these cookies remain on your computer until you either delete them or they expire.

  • Third Party cookies: these cookies are set by companies and websites that help us make Vyspa offers and promotions that we feel will be of more interest to you. These third party companies and websites are trusted and their cookies only collect anonymous data. These cookies cannot be used to find out your identity.

    When you visit third party websites, we strongly recommend that you read their applicable terms and cookie policies before using any third party website.

    You may set your Internet web browser to notify you when you receive a cookie or to prevent cookies from being sent or to search for and delete cookies stored on your hard drive. If you prevent a cookie from being sent or if you delete a cookie from your hard drive, you may limit the functionality of the Site. For more information on disabling cookies please visit www.allaboutcookies.org/manage-cookies or visit your Internet web browser's help menus.

    6. Accuracy and removing your details

    Personal Information will be updated as necessary for the purposes for which it is to be collected and used.

    Vyspa will not routinely update Personal Information unless such a process is necessary to fulfil the purposes for which the information was collected. Personal Information that is used on an on-going basis, including information that is disclosed to third parties, will generally be accurate and up-to-date to the best of Vyspa’s knowledge.

    7. Safeguards and security

    Vyspa has invested and deployed a wide variety of technology and security features to ensure the privacy of personal and anonymous information collected by it. In addition, Vyspa has implemented strict operations guidelines to safeguard Customer privacy at every level of its organisation. Unfortunately, no system is perfect; therefore, Vyspa makes no representations or warranties with regard to the sufficiency of these security measures.

    Vyspa shall not be responsible for any actual, indirect or consequential damages (or any other damages or liability of any kind whatsoever, whether as a result of negligence or otherwise) that result from a lapse in compliance with this Privacy Policy because of a security breach or technical malfunction. Nothing in this Privacy Policy shall however limit or exclude Vyspa’s liability in respect of death or personal injury caused by its negligence or for fraud.

    Vyspa protects all Personal Information regardless of the format in which it is held. The methods of protection include:

  • physical measures, such as restricted access to offices;
  • organisational measures, such as security clearances and limiting access on a "need to know" basis;
  • technological measures, such as the use of passwords and encryption.
  • 8. Accountability

    Vyspa is responsible for Personal Information under its control and has designated an individual or individuals who are accountable for the organisation's compliance with this Privacy Policy. If you have any questions or concerns in relation to this Privacy Policy Vyspa’s Privacy Officer may be contacted at privacyofficer@vyspa.com

    9. Individual access

    Access requests: Upon written request, Vyspa will inform you whether or not it holds Personal Information about you, and will provide you with the opportunity to review the Personal Information it holds and request the update or modification of the same or request its deletion in accordance with this Privacy Policy. Vyspa may charge a £10.00 fee to cover its costs in providing such data to you.

    Disclosure for legal reasons: Vyspa reserves the right to communicate such of your Personal Information as it holds to third parties which seek the disclosure of it, and which make a legally compliant request for its disclosure. Vyspa also reserves the right to communicate your Personal Information to the relevant authorities if we believe that you are involved in illegal activities or commit any breach of this Privacy Policy, which would justify such disclosure.

    Data protection information: You can obtain further information about data protection laws in the UK by visiting the Information Commissioner's website at www.informationcommissioner.gov.uk. You can search for our publicly available Data Protection Notification there, should you so wish. This Privacy Policy may be modified from time to time without notice. This policy was last updated on June 3rd, 2013.