This is the privacy notice of Visa Genie Ltd.In
this document, "we", "our", or "us" refer to Visa
Genie Ltd. We are company number 06872422 registered in England and Wales.
registered office is at 30 Morland Gardens, Southall UB1 3DY.
1. This is a notice to inform you of our policy
about all information that we record about you. It sets out the conditions
under which we may process any information that we collect from you, or that
you provide to us. It covers information that could identify you (“personal
information”) and information that could not. In the context of the law and
this notice, “process” means collect, store, transfer, use or otherwise act on
2. We regret that if there are one or more points
below with which you are not happy, your only recourse is to leave our website
3. We take seriously the protection of your privacy
and confidentiality. We understand that all visitors to our website are
entitled to know that their personal data will not be used for any purpose
unintended by them, and will not accidentally fall into the hands of a third
4. We undertake to preserve the confidentiality of
all information you provide to us, and hope that you reciprocate.
5. Our policy complies with UK law accordingly
implemented, including that required by the EU General Data Protection
6. The law requires us to tell you about your
rights and our obligations to you in regards to the processing and control of
your personal data. We do this now, by requesting that you read the information
provided at www.knowyourprivacyrights.org
7. Except as set out below, we do not share, or
sell, or disclose to a third party, any information collected through our
THE BASES ON WHICH
WE PROCESS INFORMATION ABOUT YOU
The law requires us to determine under which of six
defined bases we process different categories of your personal information, and
to notify you of the basis for each category.
If a basis on which we process your personal
information is no longer relevant then we shall immediately stop processing
If the basis changes then if required by law we
shall notify you of the change and of any new basis under which we have
determined that we can continue to process your information.
1. INFORMATION WE PROCESS BECAUSE WE HAVE A CONTRACTUAL OBLIGATION WITH
When you create an account on our website, buy a
product or service from us, or otherwise agree to our terms and conditions, a
contract is formed between you and us.
In order to carry out our obligations under that
contract we must process the information you give us. Some of this information
may be personal information.
We may use it in order to:
1.1. verify your identity for security purposes
1.2. sell products to you
1.3. provide you with our services
1.4. provide you with suggestions and advice on
products, services and how to obtain the most from using our website
We process this information on the basis there is a
contract between us, or that you have requested we use the information before
we enter into a legal contract.
Additionally, we may aggregate this information in
a general way and use it to provide class information, for example to monitor
our performance with respect to a particular service we provide. If we use it
for this purpose, you as an individual will not be personally identifiable.
We shall continue to process this information until
the contract between us ends or is terminated by either party under the terms
of the contract.
2. INFORMATION WE PROCESS WITH YOUR CONSENT
Through certain actions when otherwise there is no
contractual relationship between us, such as when you browse our website or ask
us to provide you more information about our business, including job
opportunities and our products and services, you provide your consent to us to
process information that may be personal information.
Wherever possible, we aim to obtain your explicit
consent to process this information, for example, by asking you to agree to our
Sometimes you might give your consent implicitly,
such as when you send us a message by e-mail to which you would reasonably
expect us to reply.
Except where you have consented to our use of your
information for a specific purpose, we do not use your information in any way
that would identify you personally. We may aggregate it in a general way and
use it to provide class information, for example to monitor the performance of
a particular page on our website.
If you have given us explicit permission to do so,
we may from time to time pass your name and contact information to selected
associates whom we consider may provide services or products you would find
We continue to process your information on this
basis until you withdraw your consent or it can be reasonably assumed that your
consent no longer exists.
You may withdraw your consent at any time by
instructing us visa email at email@example.com.
However, if you do so, you may not be able to use our website or our services
3. INFORMATION WE PROCESS FOR THE PURPOSES OF LEGITIMATE INTERESTS
We may process information on the basis there is a
legitimate interest, either to you or to us, of doing so.
Where we process your information on this basis, we
do after having given careful consideration to:
· whether the same objective could be achieved
through other means
· whether processing (or not processing) might
cause you harm
· whether you would expect us to process your data,
and whether you would, in the round, consider it reasonable to do so
For example, we may process your data on this basis
for the purposes of:
· record-keeping for the proper and necessary
administration of our organisation.
· responding to unsolicited communication from you
to which we believe you would expect a response
· protecting and asserting the legal rights of any
· insuring against or obtaining professional advice
that is required to manage organisational risk
· protecting your interests where we believe we
have a duty to do so
4. INFORMATION WE PROCESS BECAUSE WE HAVE A LEGAL OBLIGATION
We are subject to the law like everyone else.
Sometimes, we must process your information in order to comply with a statutory
For example, we may be required to give information
to legal authorities if they so request or if they have the proper
authorisation such as a search warrant or court order.
This may include your personal information.
SPECIFIC USES OF
INFORMATION YOU PROVIDE TO US
5. INFORMATION PROVIDED ON THE UNDERSTANDING THAT IT WILL BE SHARED WITH
A THIRD PARTY
Our website allows you to post information with a
view to that information being read, copied, downloaded, or used by other
1.1. posting a message our forum
1.2. tagging an image
1.3. clicking on an icon next to another visitor’s
message to convey your agreement, disagreement or thanks
In posting personal information, it is up to you to
satisfy yourself about the privacy level of every person who might use it.
We do not specifically use this information except
to allow it to be displayed or shared.
We do store it, and we reserve a right to use it in
the future in any way we decide.
Once your information enters the public domain, we
have no control over what any individual third party may do with it. We accept
no responsibility for their actions at any time.
Provided your request is reasonable and there is no
legal basis for us to retain it, then at our discretion we may agree to your
request to delete personal information that you have posted. You can make a
request by contacting us at firstname.lastname@example.org.
6. COMPLAINTS REGARDING CONTENT ON OUR WEBSITE
We attempt to moderate user generated content, but
we are not always able to do so as soon as that content is published.
If you complain about any of the content on our
website, we shall investigate your complaint.
If we feel it is justified or if we believe the law
requires us to do so, we shall remove the content while we investigate.
Free speech is a fundamental right, so we have to
make a judgment as to whose right will be obstructed: yours, or that of the the person who posted the content that offends you.
If we think your complaint is vexatious or without
any basis, we shall not correspond with you about it.
7. INFORMATION RELATING TO YOUR METHOD OF PAYMENT
Payment information is never taken by us or
transferred to us either through our website or otherwise.
Our employees and contractors never have access to it.
At the point of payment, you are transferred to a secure page on the website of
SagePay / PayPal or some other reputable payment service provider. That page
may be branded to look like a page on our website, but it is not controlled by
8. INFORMATION ABOUT YOUR DIRECT DEBIT
When you agree to set up a direct debit
arrangement, the information you give to us is passed to our own bank Santander
for processing according to our instructions. We do not keep a copy.
We are registered under the direct debit guarantee
scheme. This provides for the customer's bank to refund disputed payments
without question, pending further investigation.
Direct debits can only be set up for payments to
beneficiaries that are approved originators of direct debits. In order to be
approved, these beneficiaries are subjected to careful vetting procedures. Once
approved, they are required to give indemnity guarantees through their banks.
9. JOB APPLICATION AND EMPLOYMENT
If you send us information in connection with a job
application, we may keep it for up to three years in case we decide to contact
you at a later date.
If we employ you, we collect information about you
and your work from time to time throughout the period of your employment.
This information will be used only for purposes
directly relevant to your employment. After your employment has ended, we will
keep your file for six years before destroying or deleting it.
10. SENDING A MESSAGE TO OUR SUPPORT TEAM
When you contact us, whether by telephone, through
our website or by e-mail, we collect the data you have given to us in order to
reply with the information you need.
We record your request and our reply in order to
increase the efficiency of our organisation.
We keep personally identifiable information
associated with your messages, such as your name and email address so as to be
able to track our communications with you to provide a high quality service.
When we receive a complaint, we record all the
information you have given to us.
We use that information to resolve your complaint.
If your complaint reasonably requires us to contact
some other person, we may decide to give to that other person some of the
information contained in your complaint.
We do this as infrequently as possible, but it is a
matter for our sole discretion as to whether we do give information, and if we
do, what that information is.
We may also compile statistics showing information
obtained from this source to assess the level of service we provide, but not in
a way that could identify you or any other person.
12. AFFILIATE AND BUSINESS PARTNER INFORMATION
This is information given to us by you in your
capacity as an affiliate of us or as a business partner.
It allows us to recognise visitors that you have
referred to us, and to credit to you commission due for such referrals. It also
includes information that allows us to transfer commission to you.
The information is not used for any other purpose.
We undertake to preserve the confidentiality of the
information and of the terms of our relationship.
We expect any affiliate or partner to agree to
reciprocate this policy.
USE OF INFORMATION
WE COLLECT THROUGH AUTOMATED SYSTEMS WHEN YOU VISIT OUR WEBSITE
Cookies are small text files that are placed on
your computer's hard drive by your web browser when you visit any website. They
allow information gathered on one web page to be stored until it is needed for
use on another, allowing a website to provide you with a personalised
experience and the website owner with statistics about how you use the website
so that it can be improved.
Some cookies may last for a defined period of time,
such as one day or until you close your browser. Others last indefinitely.
Your web browser should allow you to delete any you
choose. It also should allow you to prevent or limit their use.
software that operates on our servers, and by software operated by third
parties whose services we use.
When you first visit our website, we ask you
not use them for your visit except to record that you have not consented to
their use for any other purpose.
their use through your browser settings, you will not be able to use all the
functionality of our website.
1.1. to track how you use our website
1.2. to record whether you have seen specific messages
we display on our website
1.3. to keep you signed in our site
1.4. to record your answers to surveys and
questionnaires on our site while you complete them
1.5. to record the conversation thread during a
live chat with our support team
14. PERSONAL IDENTIFIERS FROM YOUR BROWSING ACTIVITY
Requests by your web browser to our servers for web
pages and other content on our website are recorded.
We record information such as your geographical
location, your Internet service provider and your IP address. We also record
information about the software you are using to browse our website, such as the
type of computer or device and the screen resolution.
We use this information in aggregate to assess the
popularity of the webpages on our website and how we perform in providing
content to you.
If combined with other information we know about
you from previous visits, the data possibly could be used to identify you
personally, even if you are not signed in to our website.
15. OUR USE OF RE-MARKETING
Re-marketing involves placing a cookie on your
computer when you browse our website in order to be able to serve to you an
advert for our products or services when you visit some other website.
We may use a third party to provide us with
re-marketing services from time to time. If so, then if you have consented to
SHARING OF YOUR INFORMATION
16. INFORMATION WE OBTAIN FROM THIRD PARTIES
Although we do not disclose your personal
information to any third party (except as set out in this notice), we sometimes
receive data that is indirectly made up from your personal information from
third parties whose services we use.
No such information is personally identifiable to
17. THIRD PARTY ADVERTISING ON OUR WEBSITE
Third parties may advertise on our website. In
doing so, those parties, their agents or other companies working for them may
use technology that automatically collects information about you when their
advertisement is displayed on our website.
They may also use other technology such as cookies
We do not have control over these technologies or
the data that these parties obtain. Accordingly, this privacy notice does not
cover the information practices of these third parties.
18. CREDIT REFERENCE
To assist in combating fraud, we share information
with credit reference agencies, so far as it relates to clients or customers
who instruct their credit card issuer to cancel payment to us without having
first provided an acceptable reason to us and given us the opportunity to
refund their money.
19. DATA MAY BE PROCESSED OUTSIDE THE EUROPEAN UNION
Our websites are hosted in UK. We may also use
outsourced services in countries outside the European Union from time to time
in other aspects of our business.
Accordingly data obtained within the UK or any
other country could be processed outside the European Union.
For example, some of the software our website uses
may have been developed in the United States of America or in Australia.
We use the following safeguards with respect to
data transferred outside the European Union:
1.1. the processor is within the same corporate
group as our business or organisation and abides by the same binding corporate
rules regarding data processing.
1.2. the data protection clauses in our contracts
with data processors include transfer clauses written by or approved by a
supervisory authority in the European Union.
1.3. we are certified under an approved
certification mechanism as provided for in the GDPR
1.4. both our organisation and the processor are
public authorities between whom there is either a legally binding agreement or
administrative arrangements approved by a supervisory authority in the European
Union relating to the protection of your information
ACCESS TO YOUR OWN
20. ACCESS TO YOUR PERSONAL INFORMATION
1.1. At any time you may review or update
personally identifiable information that we hold about you, by signing in to
your account on our website.
1.2. To obtain a copy of any information that is
not provided on our website you may send us a request at email@example.com.
1.3. After receiving the request, we will tell you
when we expect to provide you with the information, and whether we require any
fee for providing it to you.
21. REMOVAL OF YOUR INFORMATION
If you wish us to remove personally identifiable
information from our website, you may contact us at firstname.lastname@example.org.
This may limit the service we can provide to you.
22. VERIFICATION OF YOUR INFORMATION
When we receive any request to access, edit or
delete personal identifiable information we shall first take reasonable steps
to verify your identity before granting you access or otherwise taking any
action. This is important to safeguard your information.
23. USE OF SITE BY CHILDREN
1.1. We do not sell products or provide services
for purchase by children, nor do we market to children.
1.2. If you are under 18, you may use our website
only with consent from a parent or guardian
24. ENCRYPTION OF DATA SENT BETWEEN US
We use Secure Sockets Layer (SSL) certificates to
verify our identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you
can check that it is done so using SSL by looking for a closed padlock symbol
or other trust mark in your browser’s URL bar or toolbar.
25. HOW YOU CAN COMPLAIN
or if have any complaint then you should tell us by email. Our address is
1.2. If a dispute is not settled then we hope you
will agree to attempt to resolve it by engaging in good faith with us in a
process of mediation or arbitration.
1.3. If you are in any way dissatisfied about how
we process your personal information, you have a right to lodge a complaint
with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/
26. RETENTION PERIOD FOR PERSONAL DATA
Except as otherwise mentioned in this privacy
notice, we keep your personal information only for as long as required by us:
1.1. to provide you with the services you have
1.2. to comply with other law, including for the
period demanded by our tax authorities;
1.3. to support a claim or defence in court
27. COMPLIANCE WITH THE LAW
comply with the law of every country or legal jurisdiction in which we aim to
do business. If you think it fails to satisfy the law of your jurisdiction, we
should like to hear from you.
However, ultimately it is your choice as to whether
you wish to use our website.
We may update this privacy notice from time to time
as necessary. The terms that apply to you are those posted here on our website
on the day you use our website. We advise you to print a copy for your records.
If you have any question regarding our privacy
policy, please contact us.