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PRIVACY POLICY


WHO WE ARE



Compliance Online Limited, trading as VIXIO Regulatory Intelligence (“we”;
“us”), is committed to protecting and respecting your privacy. This Privacy
Policy (“policy”) forms part of and is incorporated by reference into Compliance
Online Limited’s standard Terms and Conditions.



This policy governs the data which we collect from users and other third parties
in the course of our business and the way in which we protect and process such
information. Please read this policy carefully to understand how we will treat
your personal data.



Last updated: January 2020



1. DATA CONTROLLER



For the purpose of the General Data Protection Regulation (the “GDPR”), which
applies in the UK on May 25, 2018, and other data protection laws applicable in
the UK, the data controller is Compliance Online Limited (Company Registration
05706431), having its registered address at St Clare House, 33 Minories, London,
EC3N1DD.



2. INFORMATION WE MAY COLLECT ABOUT YOU



Data regarding you and your business is collected, retained and processed
subject to and in accordance with the requirements of the GDPR. We may collect
personal data, that includes: name, job title, contact information including
email address and mailing address, telephone number, demographic information
such as postcode, preferences and interests, employer details, pay
data/information, IP address, other information relevant to customer surveys
and/or offers.



We may collect and process the following data about you:



(a) Information you provide when you use our website www.vixio.com (the
“website”). This includes information provided by you at the time you place an
order for any of our products or services. We may also ask you for information
if you report a problem with our website.



(b) If you contact us by email, through our contact form, by telephone or in
writing, We may keep a copy of that correspondence or communication.



(c) Details of any transactions you carry out with us through the website or by
any other means, including those contained in an order form, and of fulfilment
of your orders.



(d) Details of your visits to the website and the resources that you access.



If you have provided us with the personal data of another person, you confirm
that he/she consents to the processing of his/her personal data and that you
have informed him/her of our identity as a data controller and provided him/her
with a copy of our Terms and Conditions and this policy.



We also monitor visitors to and content on our message board and blog sites to
meet our obligations to ensure that rules as to content are being followed. We
will review and, if appropriate, edit content on these sites.



3. IP ADDRESSES AND COOKIES



We may collect information about your mobile phone, computer or other device
from which you access the website. Such information may include your domain name
and IP address, details of your computer operating system and browser, the
website you visited prior to visiting our website and unique number identifiers
that are automatically generated by our systems when you visit our website. This
will include details of the choices you make on our website indicating whether
you wish to receive information on other products and services.



Some of this information is retained in “cookie” files on your computer. These
files retain useful information that can speed your navigation through
frequently visited sites. They can also retain records that track site usage,
preferences and passwords. These cookies can be disabled or deleted by
activating the setting on your browser if you do not wish them to be used.
However, if you select this setting you may be unable to access certain parts of
our website. Unless you have adjusted your browser setting so that it will
refuse cookies, our system will issue cookies when you log in to our website.



Please note that our advertisers may also use cookies, over which we have no
control.



4. LEGAL BASIS FOR DATA PROCESSING



We can process personal data on various legal bases.



For processing operations for which we obtain consent for a specific processing
purpose, Article 6(1)(a) of the GDPR is our legal basis.



If the processing of personal data is necessary for the performance of a
contract to which the data subject is party, as for example when processing
operations necessary to provide our service, the processing is based on Article
6(1)(b) of the GDPR. The same applies to such processing operations which are
necessary for carrying out pre-contractual measures, for example in the case of
inquiries concerning our products or services.



If our company is subject to a legal obligation by which processing of personal
data is required, such as for the fulfilment of tax obligations, our processing
is based on Article 6(1)(c) of the GDPR.



Finally, we can base our processing operations on Article 6(1)(f) of the GDPR:
this legal basis is used for processing operations which are not covered by the
abovementioned legal grounds, if processing is necessary for the purposes of the
legitimate interests pursued by our company or by a third party, except where
such interests are overridden by the interests or fundamental rights and
freedoms of the data subject which require protection of personal data.



5. RETENTION OF YOUR INFORMATION



We take appropriate measures to ensure that any information collected from you
is kept only for so long as is necessary for the purpose for which such
information is used.



We normally update your personal data within seven (7) working days of any new
or updated personal data being provided to us, to ensure that the personal data
we hold about you is as accurate as possible.



We protect your data by:



Offering you a secure transmission method to send us personal or company
information.



Implementing security policies and technical measures to protect data from:



 * unauthorised access;
 * improper use or disclosure;
 * unauthorised modification; and
 * unlawful destruction or accidental loss.



6. USES MADE OF YOUR INFORMATION



We use the information collected about you for the following purposes:



 * To ensure the products and services you have chosen are delivered to you in
   the most effective way, and to assist with the performance of our internal
   contract, accounting and administrative functions.
 * To carry out our obligations arising from any contracts entered into between
   you and us.
 * To report aggregate information to our advertisers. This is statistical data
   about our users’ browsing actions and patterns and does not identify any
   individual.
 * To assist us in developing new and improved products as indicated by user
   practice and preferences, based on our analysis of patterns of site usage.
 * To provide you with details of changes to our products or of other product
   offerings which we believe may be of interest to you from GamblingCompliance
   or other third-party providers. We will not share your data with third
   parties for marketing purposes unless we have procured your express consent
   to do so.



7. PROFILING OR OTHER AUTOMATED INDIVIDUAL DECISION MAKING



Automated individual decision making refers to a decision made solely on the
basis of automated processing of your personal data, without human involvement.
For instance, this means processing using an algorithm or a software code.
Profiling is defined as automated processing of personal data to evaluate
certain things about an individual: profiling can be part of an automated
decision-making process.



We may conduct automated decision making or profiling to better understand your
centre of interests and preferences and adapt our communications to your
profile. However, we want you to know that you have certain rights in respect of
automated decision making and profiling, where that decision produces a legal
effect on you. Please see below the section on “Your rights under the GDPR” for
more information about your rights.



8. RETENTION OF YOUR INFORMATION



We take appropriate measures to ensure that any information collected from you
is kept only for so long as is necessary for the purpose for which such
information is used.



We normally update your personal data within seven (7) working days of any new
or updated personal data being provided to us, to ensure that the personal data
we hold about you is as accurate as possible.



We protect your data by:



Offering you a secure transmission method to send us personal or company
information.



Implementing security policies and technical measures to protect data from:



 * unauthorised access;
 * improper use or disclosure;
 * unauthorised modification; and
 * unlawful destruction or accidental loss.



 



9. DISCLOSURE OF YOUR INFORMATION



We may disclose your personal information to any member of our group, which
means our subsidiaries, our ultimate holding company and its subsidiaries as
defined in Section 1159 of the UK Companies Act 2006.



We may disclose your personal information to third parties:



(a) In the event that we sell or buy any business or assets, in which case we
may disclose your personal data to the prospective seller or buyer of such
business or assets.



(b) If we or substantially all of our assets are acquired by a third party, in
which case personal data held about our customers will be one of the transferred
assets.



(c) If we are under a duty to disclose or share your personal data to comply
with any legal obligation.



(d) To enforce or apply our Terms and Conditions and other agreements.



(e) If it is required to do so to deliver our services. We sometimes outsource
certain functions of our business to service providers: some of these service
providers may use cloud-based systems: in that case, your personal data would be
hosted on their servers, but under our direction and control.



f) Where we have received your permission for us to do so.



10. TRANSFERS OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)



We will only transfer your personal data to countries which are considered as
providing an adequate level of legal protection or where alternative
arrangements are in place to protect your rights.



We may transfer your personal data outside the EEA in the unlikely event that we
receive a legal request from a foreign law enforcement body. All requests for
information we receive from these bodies will be carefully checked before
personal data is transferred.



We may use remote website server hosts to provide and maintain some aspects of
our service and website, which may be based outside the EEA (in “the cloud”).
Transfers to service providers outside of the EEA will be protected by
contractual commitments and, where appropriate, further assurances, such as
certification schemes (including the EU-US Privacy Shield for the protection of
personal data transferred from the EU to the US and accessed in the US).



You have the right to ask for more information about the safeguards we have put
in place as mentioned above.Your rights under the GDPR



11. RIGHT OF ACCESS



Right of access



The GDPR gives you the right to access information held about you. If you wish
to exercise such right, please submit a request to us in writing at
dataprotection@vixio.com.



Any access request shall be subject to your providing acceptable proof of
identification.



If we are processing your personal data, we will provide you with a copy of that
personal data.



If you require additional copies, we may charge a reasonable administrative fee.



Right of rectification



You are entitled to have your personal data rectified if it is inaccurate or
incomplete. You should instruct us to correct or update any personal data we
hold about you (for instance, if you change your address or your name).



You can instruct us to do this at any time by contacting us at
dataprotection@vixio.com.



Right to erasure



You have a right to have your personal data erased and to prevent processing in
specific circumstances. If you wish to exercise such right, please submit a
request to us in writing at dataprotection@vixio.com.



Right to restrict processing



In certain circumstances, you have the right to obtain from us restriction of
processing (especially when the accuracy of the personal data is contested by
you, for a period enabling us to verify the accuracy of the personal data).



Right to withdraw your consent



In certain circumstances, we must have your consent before we contact you. You
have the right to withdraw your consent to processing of your personal data at
any time by contacting us at dataprotection@vixio.com.



Right to data portability



With effect from May 25, 2018, you have the right, in certain circumstances, to
obtain personal data you have provided us with, in a structured, commonly used
and machine-readable format, and to reuse it elsewhere or ask us to transfer
this to a third party of your choice.



Right to object



You have the right to object to:



 * Processing based on legitimate interests or the performance of a task in the
   public interest/exercise of official authority (including profiling).
 * Direct marketing (including profiling).
 * Processing for purposes of scientific/historical research and statistics.



Rights related to automated decision making and profiling



You have the right not to be subject to a decision based solely on automated
processing, including profiling, which produces legal effects concerning you or
similarly significantly affects you, as long as the decision is not necessary
for entering into, or the performance of, a contract between you and us; or is
not based on your explicit consent.



Right to lodge a complaint with a supervisory authority



You have a right to lodge a complaint with a supervisory authority, to enforce
your rights, as specified above. You can find details about how to do this on
the UK Information Commissioner’s Office (ICO) website at
https://ico.org.uk/concerns/.



12. LINKS TO OTHER WEBSITES



Our website offers links to many third-party websites. We are not responsible
for the accuracy or efficacy of the information or data policies or procedures
of these third parties. If you access these sites using the links provided on
our website, you should satisfy yourself as to the relevant data policies in
effect on these sites.



13. CHANGES TO OUR PRIVACY POLICY



Any changes we may make to our Privacy Policy in the future will be posted on
this page and on our website. Please check this page occasionally to ensure you
are happy with any changes.



If you have any questions about our privacy policy, or if you want to request
information about our privacy policy, please contact us at
dataprotection@vixio.com or in writing at the address set out on the Contact Us
page of the website.



14. CONTACT



If any of your personal data changes, or if you have any questions, comments or
requests regarding the protection of your personal data or this policy, please
contact us by email at dataprotection@vixio.com or in writing at the address set
out on the Contact Us page of the website.

 





Compliance Online Limited, trading as VIXIO Regulatory Intelligence (“we”;
“us”), is committed to protecting and respecting your privacy. This Privacy
Policy (“policy”) forms part of and is incorporated by reference into Compliance
Online Limited’s standard Terms and Conditions.

 

At VIXIO, we consider the security of our systems a top priority. But no matter
how much effort we put into system security, there can still be vulnerabilities
present.

If you discover a vulnerability, we would like to know about it so we can take
steps to address it as quickly as possible. We would like to ask you to help us
better protect our clients and our systems.

Please do the following:

 * E-mail your findings to tech@vixio.com. Encrypt your findings using our PGP
   key to prevent this critical information from falling into the wrong hands,
 * Do not take advantage of the vulnerability or problem you have discovered,
   for example by downloading more data than necessary to demonstrate the
   vulnerability or deleting or modifying other people’s data,
 * Do not reveal the problem to others until it has been resolved,
 * Do not use attacks on physical security, social engineering, distributed
   denial of service, spam or applications of third parties, and
 * Do provide sufficient information to reproduce the problem, so we will be
   able to resolve it as quickly as possible. Usually, the IP address or the URL
   of the affected system and a description of the vulnerability will be
   sufficient, but complex vulnerabilities may require further explanation.

What we promise:

 * We will respond to your report within 3 business days with our evaluation of
   the report and an expected resolution date,
 * If you have followed the instructions above, we will not take any legal
   action against you in regard to the report,
 * We will handle your report with strict confidentiality, and not pass on your
   personal details to third parties without your permission,
 * We will keep you informed of the progress towards resolving the problem,
 * In the public information concerning the problem reported, we will give your
   name as the discoverer of the problem (unless you desire otherwise).

We strive to resolve all problems as quickly as possible, and we would like to
play an active role in the ultimate publication on the problem after it is
resolved.




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United Kingdom
St Clare House,
30 Minories,
London, EC3N 1DD
+44 (0)207 921 9980

United States of America
1250 Connecticut Avenue,
NW Suite 700
Washington D.C., 20036
+1 202 261 3567


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