Privacy policy

Welcome to Strongbyte Solutions Limited’s privacy policy. Strongbyte Solutions Limited, trading as VoCoVo, is committed to protecting your personal data and respecting your privacy. VoCoVo is also referred to as we, us throughout this policy.

This privacy policy explains how we collect, use, share and look after your personal data when you:

• visit our website www.vocovo.com (http://www.vocovo.com) (Website), regardless of where you visit it from;
• use our customer portal, portal.vocovo.com (Portal); or
• make use of our software application known as VoCoVo Link (App), once you have downloaded a copy of the App onto your mobile telephone, tablet or other handheld device (Device).

Our App is hosted on the AppStore and on Google Play. We issue frequent updates to our app, please see the latest version in the “About this App” area of the app.

Our separate end-user licence agreement (EULA) and any additional terms incorporated into our EULA (together, our Terms of Use) apply to your use of any services which are available and accessible through the App (Services). A copy of our Terms of Use is available here.

Our App is not intended for children, and we do not knowingly collect data relating to children.

This policy tells you about your privacy rights and how the law protects you. Please read it carefully to understand our practices regarding your personal data and how we will treat it.

Our policy is provided in a layered format, so you can easily navigate to each of the specific sections listed.

Purpose of this privacy policy

This privacy policy aims to give you information on how VoCoVo collects and processes your personal data through your use of our Website, our Portal or our App, including any data you may provide through our Website, Portal or App. It applies to our website users, customers, Portal users, App users and suppliers. Where applicable, this policy contains specific sections addressed to some but not all of these specific groups of users. Please review the sections relevant to you.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide (for example, on specific occasions when we are collecting or processing personal data about you), so that you are fully aware of how and why we are using your data. This privacy policy supplements all other notices and is not intended to override them.

Children

Our Website, Portal and App are not intended for children, and we do not knowingly collect data relating to children.

Controller

We (Strongbyte Solutions Limited, trading as VoCoVo) are the ‘controller’ of your personal data and we are responsible for it.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions related to this privacy policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the DPO using the contact details set out in the next section.

Processing on behalf of business customers

Please note that in some cases (for example where your personal data is processed for our User Enrolment services), we process personal data for and on behalf of our business customers. Where this is the case, our business customer is the relevant ‘controller’ for the purposes of data protection law, which means that they are ultimately responsible for your personal data. You should therefore direct any query about that processing to the relevant business customer.

If you require more information about how any of our business customers collect and process your personal data, please refer to their separate privacy notices displayed on their separate websites. If you are not sure who the relevant controller is, please contact us via our DPO and we will do our best to assist you.

Contact details

Our full details are as follows:

Full name of legal entity: Strongbyte Solutions Limited (company number 07768497)

Registered office: Unit 7 Wychwood Business Centre, Milton Road, Shipton Under Wychwood, Oxfordshire, OX7 6XU

Name or title of DPO: Herbert Bosin, IT Manager and DPO

Email address: [email protected] (mailto:[email protected])

Postal address: Unit 7 Wychwood Business Centre, Milton Road, Shipton Under Wychwood, Oxfordshire, OX7 6XU

Telephone number: +44 (0)3301 373789

Our obligations

Data protection law requires VoCoVo, as controller of your data, to:

• process your data in a lawful, fair and transparent way;
• only collect your data for explicit and legitimate purposes;
• only collect data that is relevant, and limited to the purpose(s) we have told you about.
• ensure that your data is accurate and up to date;
• ensure that your data is only kept as long as necessary for the purpose(s) we have told you about;
• ensure that appropriate security measures are used to protect your data.

Changes to this privacy policy

We regularly review our privacy policy. This version was last updated on 7 September 2024. Historic versions can be obtained by contacting us using the above details.

Your duty to update us

It is important that the personal data we hold about you is accurate and current. We may ask you to confirm updates to your personal data from time to time. In the meantime, please keep us informed using the email address above if your personal data changes during your relationship with us.

Third-party links

Our Website, Portal and App 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 also have a social media presence for the purpose of engaging with you.

If you enable links or connections or choose to communicate your personal data to us via third-party websites or social media, please remember that we do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, Portal or App or interact with us on social media, we encourage you to read the privacy policy of every website or social media forum that you visit or use.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together follows:

• Identity Data includes first name, last name, username or similar identifier, job title, company phone number and photographs.
• Contact Data includes billing address, address, email address and telephone numbers.
• Technical Data includes 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 our Website, Portal or App.
• Device Data: This includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, and your time zone setting.
• Profile Data includes your username and password.
• Usage Data includes information about how you use our Website, Portal and/or App (as applicable to you), including your user preferences.
• Communications Data includes your communication preferences.

We refer to the above categories of data when describing the purposes for which we will use your personal data. These purposes are described further down in this policy.

Where you represent a business, much of the data we collect is likely to relate to that business rather than you personally (for example, if that business is a customer of VoCoVo, we are likely to collect transaction data relating to that business rather than you). However, this privacy policy applies to the extent that we collect any personal data about you in connection with our relationship with that business – including, for example, Contact Data (as your business email address may contain your personal data). If you have any questions about what personal data we collect about you, please contact us using our contact details set out in the section above.

Other types of data

We also collect, use and share Aggregated Data, such as statistical or demographic data, regarding the behaviour of our website users. Aggregated Data may be derived from your personal data but is not considered personal data in law, because this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.

If we combine or connect Aggregated Data with your personal data, so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • order our products or services;
  • create an account on our Website, Portal or App;
  • subscribe to our service;
  • enter a competition, promotion or survey;
  • give us some feedback or contact us.
  • if you or your employer sets you up as a user of our Portal.
• Automated technologies or interactions. As you interact with our Website, Portal or App, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• 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.

Generally, unless otherwise stated in this policy, we do not rely on consent as a legal basis for processing your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have explained our legitimate interests where appropriate.

Note that we may process your personal data for more than one legal basis, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying upon, where more than one basis has been given.

Please review the table(s) relevant to you, using the links below. Note that there may be more than one table that is relevant to you (for example, if you are a Website user and a customer of VoCoVo).

Website users

If you use our Website, this section applies to you.

Customers (and prospective customers)

If you (or your business or organisation) are a customer or prospective customer of VoCoVo, this section applies to you.

Portal users

If you use our Portal, this section applies to you.

App users

If you use our App, this section applies to you.

Suppliers

If you (or your business or organisation) are a supplier of VoCoVo, this section applies to you.

MARKETING TO BUSINESS CUSTOMERS (ONLY)

As explained earlier in this policy (see the section headed ‘How we use your personal data’), we do not directly market to individuals (we only market to our business customers as corporate subscribers). Accordingly, individuals will not receive any marketing communications from us.

Only our business customers (as corporate subscribers) will receive marketing communications from us if you (as one of our business customers) have requested information from us or purchased goods or services from us and, in each case, your business has not opted out of receiving that marketing.

Third-party marketing

We do not share your personal data with any company outside of VoCoVo for marketing purposes.

Opting out

Business customers who receive marketing messages can contact us using the above details at any time to ask us to stop sending them.

Where you (as a business customer) opt out of receiving marketing messages, this will not apply to personal data (if and to the very limited extent that any is provided to us) in connection with your business’ product/service purchase, warranty registration, product/service experience or other transactions.

COOKIES

Cookies on our Website

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 our Website may become inaccessible or not function properly. For more information about the cookies we use on our Website, please see our Cookie policy.

Cookies on our App

We use cookies within our App to distinguish you from other users of the App and to remember your preferences. This helps us to provide you with a good experience when you use the App and allows us to improve it. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

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 get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us (https://docs.google.com/document/d/16DcxefUhad5pDG_d5g2lRs9QP_rVH9SBZIh9P2DQTto/edit#bookmark=id.2xcytpi).

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the following parties for the purposes set out in the tables above:

• External Third Parties (see the section headed ‘Third Parties’ below.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy or they may write to you to update you regarding any changes to how they will use your personal data.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We do not transfer any personal information we collect about you outside the UK.

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. 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.

Portal and App users

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Portal or App, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes for which we collected it, including 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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances, you can ask us to delete your data (see your legal rights below) for further information.

In some circumstances 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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• 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.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

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.

What we may need from you

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.

Time limit to respond

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.

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

• The service providers listed in the tables above (see the section headed ‘Purposes for which we use your personal data’) as third party processors who provide the services listed in the relevant tables.
• Any professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors and insurers who may provide consultancy, banking, legal, insurance and accounting services from time to time.
• HM Revenue & Customs and any regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data corrected, though we may need to verify the accuracy of the new data you provide to us.

Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.