Privacy Policy

Background

Vortex Risk Ltd takes your right to privacy very seriously.  This Privacy Policy explains how we handle and treat your data when you visit our Site and/or contact us directly. This includes any data you may provide us through this Site or initiate an enquiry.

Personal data, or personal information, refers to any information about an individual from which that person can be identified. It does not include data where the identity has been anonymised.

www.vortexrisk.com (the “Site”) is owned and operated by Vortex Risk Ltd. Vortex Risk Ltd is the data controller and can be contacted at [email protected]

The company is registered at Capital Office 124-128 City Road, London, EC1V 2NX, United Kingdom.

Vortex Risk Ltd is collectively referred to in this Privacy Policy as “we,” “us” or “our”.

Purpose

The purpose of this Privacy Policy is to inform users of our Site of the following:

1. The personal data we will collect;
2. Use of collected data;
3. Who has access to the data collected; and
4. The rights of Site users.

This Privacy Policy applies in addition to the terms and conditions of our Site.

GDPR

For users in the European Union, we adhere to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, known as the General Data Protection Regulation (the “GDPR”). For users in the United Kingdom, we adhere to the GDPR as enshrined in the Data Protection Act 2018.

We have not appointed a Data Protection Officer as we do not fall, at this time, within the categories of controllers and processors required to appoint a Data Protection Officer under Article 37 of the GDPR.

Consent

By using our Site users agree that they consent to the:

1. The conditions set out in this Privacy Policy. When the legal basis for us processing your personal data is that you have provided your consent to that processing, you may withdraw your consent at any time. If you withdraw your consent, it will not make processing which we completed before you withdrew your consent unlawful.

You can withdraw your consent by emailing “STOP” to [email protected]

Legal Basis for Processing

We collect and process personal data about users in the EU only when we have a legal basis for doing so under Article 6 of the GDPR.

We rely on the following legal basis to collect and process the personal data of users in the EU:

1. Users have provided their consent to the processing of their data for one of more specific purposes.

Personal Data We Collect

We only collect data that helps us achieve the purpose set out in this Privacy Policy. We will not collect any additional data beyond the data listed below without notifying you first.

Data Collected in an Automatic Way

1. Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
2. Information about how you use our Site.

Aggregated Data such as statistical or demographic data derived from your personal data is not considered personal data in law as this data will not directly or indirectly reveal your identity.

We do not collect any Special Categories of Personal Data about you such as race, ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data, and criminal convictions and offences.

This data may be collected using the following methods:

1. Using cookies and other similar technologies.
   1. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly.
2. From third-parties such as:
   1. analytics providers such as Google based outside the EU;
   2. search information providers such as Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

Data Collected in the Non-Automatic Way

We may also collect the following data when you perform certain functions on our Site or engage with us directly:

1. Identity information such as first and last name;
2. Contact information such as billing address, delivery address, email address and telephone numbers;
3. Company you work for, represent, or are affiliated with;
4. Details about payments (bank account and payment card details) to and from you and other details of products and services you have purchased from us.

This data may be collected using the following methods:

1. When you fill in forms or correspond with us by post, phone, email or otherwise.
2. Contract us for our products or services.

How We Use Personal Data

Data collected on our Site or by you engaging with us directly will only be used for the purposes specified in this Privacy Policy or indicated on the relevant page of our Site. We will not use your data beyond what we disclosed in this Privacy Policy.

The data we collect when the user performs certain functions may be used for the following purposes:

1. Where we need to perform the contract we are about to enter into or have entered into with you;
2. Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
3. Operating and managing our business operations justified based on our legitimate interests for ensuring the proper functioning of our business operations;
4. Complying with legal requirements;
5. Monitoring your use of our Site and any apps and tools you use that are on it;
6. To administer and protect our business and this Site including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data;
7. To deliver relevant Site content, marketing, and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
8. To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences;
9. Communicating with you to provide you with the requested information, follow up on communications initiated by you, and in case of emergency;
10. To provide you with marketing and promotion offers from us based on what we view you may want or need, or what may be of interest to you.

Who We Share Personal Data With

Employees

We may disclose user data to any member of our organisation who reasonably needs access to user data to achieve the purposes set out in this Privacy Policy.

Other Disclosures

We will not sell or share your data with other third parties, except in the following cases:

1. If the law requires it;
2. If it is required for any legal proceeding;
3. To prove and protect our legal rights; and
4. To buyers or potential buyers of this company in the event that we seek to sell the company;
5. With our professional advisers such as lawyers and accountants;
6. Third-party service providers to assist us with client insight analytics, such as Google Analytics;
7. Third-party postal or courier providers who assist us with postal needs;
8. Please note this list is non-exhaustive and there may be other examples that we need to share with other parties to provide the Services as effectively as we can.

This Site may include links to third-party websites, plug-ins and applications. If you follow hyperlinks from our Site to another Site, please note that we are not responsible for and have no control over their privacy policy and practices.

How Long We Store Personal Data

User data will be stored until the purpose the data was collected for has been achieved.

You will be notified if your data is kept for longer than this period.

How We Protect Your Personal Data

We store your data in a secure location. All data is only accessible to our employees. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee’s termination.

While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The Internet as a whole can be insecure at times and therefore we are unable to guarantee the security of the user data beyond what is reasonably practical.

Your Rights as a User

Under the GDPR, you have the following rights:

1. Right to be informed;
2. Right of access;
3. Right to rectification;
4. Right to erasure;
5. Right to restrict processing;
6. Right to data portability; and
7. Right to object.

Children

We do not knowingly collect or use personal data from children under 16 years of age. If we learn that we have collected personal data from a child under 16 years of age, the personal data will be deleted as soon as possible. If a child under 16 years of age has provided us with personal data their parent or guardian may contact our privacy officer.

How to Access, Modify, Delete, or Challenge the Data Collected

If you would like to know if we have collected your personal data, how we have used your personal data, if we have disclosed your personal data and to whom we disclosed your personal data, you would like your data to be deleted or modified in any way, or if you would like to exercise any of your other rights under GDPR, please contact our privacy officer here:

Mariola Marzouk

[email protected]

Capital Office 124-128 City Road, London, EC1V 2NX, United Kingdom

Cookies

Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. By continuing to browse the Site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

1. Strictly necessary cookies – these are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.
2. Analytical/performance cookies – they allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
3. Functionality cookies – these are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
4. Targeting cookies – these cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site.

You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access our Site more quickly and efficiently.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

Modifications

This Privacy Policy may be amended from time to time to maintain compliance with the law and to reflect any changes to our data collection process.  When we amend this Privacy Policy we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates.  If necessary, we may notify users by email of changes to this Privacy Policy.

Complaints

If you have any complaints about how we process your personal data, please contact us through the contact methods listed in the Contact Information section so that we can, where possible, resolve the issue. If you feel we have not addressed your concern satisfactorily you may contact a supervisory authority. You also have the right to directly make a complaint to a supervisory authority.  You can lodge a complaint with a supervisory authority by contacting the Information Commissioner’s Office in the UK (www.ico.org.uk), the Data Protection Commission in Ireland (www.dataprotection.ie).

Contact Information

If you have any questions, concerns or complaints, you can contact our privacy officer, Mariola Marzouk, at:

[email protected]

Capital Office 124-128 City Road, London, EC1V 2NX, United Kingdom