GDPR Version 1: 21st June 2019
We appreciate your interest in our products and services and your visit to this website.
Your privacy is important to us and we want you to feel comfortable with how we use and share your personal information.
You do not have to give us any personal information in order to use this website.
However, if you wish to register on this site, subscribe to a service, request further information, purchase / enquire about a product or service, sign up to our newsletter or take part in a specific promotional campaign, prize draw or competition, we may collect:
Your name, eMail address, phone number and possibly your physical address.
A record of financial transactions where applicable, however we do not directly, collect, process or store debit or credit card information.
Online Payments made through this website are processed securely by third-party payment providers Stripe and Paypal.
We may also automatically collect information about the website you came from or are moving to, the pages you visit on our website, IP address data, the type of browser used and the time of site access. This information will be aggregated and not used to identify you directly.
By providing us with your data, you warrant to us that you are over 13 years of age.
Full name of legal entity: Russo Giuseppe
Giuseppe Russo – Founder
Email address: mailto:email@example.com
WHAT DATA DO WE COLLECT ABOUT YOU?
Personal data means any information capable of identifying an individual. It does not include anonymised data. We may process certain (applicable) types of personal data about you as follows:
Identity Data may include: your first name, maiden name, last name, username, marital status, title, date of birth and gender.
Contact Data may include: your billing address, delivery address, email address and telephone numbers.
Financial Data may include: your bank account and payment card details.
Transaction Data may include: details about payments between us and other details of purchases made by you.
Technical Data may include: your login data, internet protocol (IP) addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
Profile Data may include: your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
Usage Data may include: information about how you use our website, products and services.
Marketing and Communications Data may include: your preferences in receiving marketing communications from us and our third parties and your communication preferences.
Sensitive Data: We do not collect any Sensitive Data about you. Sensitive data refers to data that 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.
We do not collect any information about criminal convictions and offences.
HOW WE COLLECT YOUR PERSONAL DATA
We collect data about you through a variety of different methods including:
Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email, livechat or otherwise, including when you:
order our products or services or create an account on our site;
subscribe to our service or publications or request resources or marketing be sent to you;
enter a competition, prize draw, promotion or survey; or provide feedback.
Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns.
We collect this data by using cookies, server logs and similar technologies.
We may also receive Technical Data about you if you visit other websites that use our cookies.
Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
analytics providers such as Google based outside the EU;
advertising networks which we may utilise from time-to-time
Contact, Financial & Transaction Data from technical, payment & delivery service providers.
Identity & Contact Data from publicly available sources.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
Where we need to perform the contract between us.
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 or regulatory obligation.
Provide the products and services or communicate with you as requested
Administer our website and provide customer services
Gather management, statistical and trend analysis information
Investigate any complaints
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by emailing us at:
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions or where we have a legal obligation to retain your financial transaction data.
PURPOSES FOR PROCESSING YOUR PERSONAL DATA
We have listed below examples of how we intend to use your personal data and the legal grounds on which we will process such data including our legitimate interests to do so where relevant.
Note: We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data.
Type of data
Lawful basis for processing
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
(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 analyse how customers use our products / services
To enable you to partake in a prize draw, competition or complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests and to analyse how customers use our products / services.
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security and to prevent fraud.
(b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
(e) Marketing and Communications
Necessary for our legitimate interests to analyse how customers use our products / services.
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop 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
Necessary for our legitimate interests to develop our products/services and grow our business
You will receive relevant marketing communications from us if you have:
requested information from us or purchased goods or services from us; or
if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
in each case, you have not opted out or unsubscribed from receipt of that marketing.
We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at: mailto:firstname.lastname@example.org
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may be required to share your personal data with the parties set out below for the purposes set out in the table above:
Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
Government authorities, in the United States and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law.
We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
3rd PARRTY SUPPLIERS: Transfer and storage of your information
eCommerce Platform: Thrivecart
We use Thrivecart as the ecommerce platform for processing orders on our website.
When you place orders on our website, your information will be processed by Thrivecart.
Thrivecart does not collect any information about you when it processes your order on our site.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised 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 such data.
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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 unauthorised 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 requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances:
you can ask us to delete your data: see below for further information.
we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data.
Right to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights).
However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).
This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests.
In this case, we will notify you and keep you updated.
This website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our website, we encourage you to read the privacy notice of every website you visit.
Cookies and Google:
Google Analytics cookies are classified as first party cookies as they are set by our website domain, although Google collects and processes information from our use of Google Analytics.
For information on how Google uses data from cookies it uses, click here
Providing information to Google Inc.
Google collects information through our use of Google Analytics on our website.
Google uses this information, including IP addresses and information from cookies, for a number of purposes. Information is shared with Google on an aggregated and anonymised basis.
Providing information to 3rd party organisations:
Accountants: Our UK based accountants receive shared information required for tax purposes. For example, invoices we issue and receive for the purpose of completing tax returns and end of year accounts.
Business partners: Our partners may include UK based businesses we work with which provide goods and services complementary to our own or which allow us to provide goods or services which we could not provide.
Independent contractors: Occasionally, we may use independent contractors to support our business. Your information may be shared with independent UK contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.
Transmission of information to use by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Transfers of your information outside the European Economic Area Your information may be transferred and stored outside the European Economic Area (EEA) in the certain circumstances. Where we are required to do so, we will ensure appropriate safeguards and protections are in place.
We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.
Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.
At Vortex Digital Services, we believe in being fully transparent offering details on how we collect and use any data related to you personally.
Explaining a “cookie”: A cookie is a small file placed onto your device that enables us to identify your device and secure your access.
There are two main types of cookie: persistent cookies & session cookies.
A persistent cookie will recognise you as an existing user: e.g. can remove the need to sign in each time you visit the site.
Session cookies will only apply for as long as your current website visit or browser session.
These cookies are essential to allow you to move around our website, remember login or registration details and shopping cart information (where applicable).
A system for collection of anonymous information on how our site visitors use of website (i.e. Google Analytics). This data does not store or retain any identifiable personal data.
Again, these cookies collection anonymised information to remember; Relevant information including the Country you visit the site from, language preference, product line search preferences.
Targeting or Advertising Cookies:
These cookies are usually placed by third-party advertising networks aimed to remember sites you visit and to deliver relevant advertising targeted at your areas of interest.
Social Media Cookies:
Social Media Cookies are not within our control and allow you to share your website interaction on social media channels including Facebook, Twitter etc. Please refer to their respective privacy policies.
Web beacons collect anonymised and limited information to track campaign effectiveness.
The privacy use of a Cookie is compliant with the General Data protection Regulations (GDPR).
Authenticate: To deliver the most appropriate information and personal experience.
Security: Tailored to support security features and to identify malicious activity.
Preferences, features and services: To identify language and communications preferences, aid easier form completion and customise content.
Advertising: To deliver relevant advertising and provide retargeting to visitors who saw an ad, took action, completed a purchase or a download.
Performance, Analytics and Research: To aid research and analytics to understand and improve, products, features and services.
Cookies and Advertising
Cookies, pixels and tags help to serve relevant ads to visitors by identifying your device, your usage, your browsing behaviour, log data (your IP address).
The General Data Protection Regulations (GDPR) governs the use of personal information and information collected cannot be shared with any 3rd party advertisers without your consent.
The use and Control of Cookies and third-party cookies
You can control cookies through your browser settings preferences.
To decline to receive cookies, simply change your browser settings on your computer or other device. Most browsers also provide functionality that lets you review and erase cookies.
3 Vine Street Ltd can provide details of the third-party cookies that may be used on our site.
Browser manufacturers provide help pages relating to cookie management in their products.
Please see below for more information.
For other browsers, please consult the documentation that your browser manufacturer provides.