Last updated July 28, 2022
- how we look after your personal data,
- your privacy rights,
- how the law protects you.
The policy is a layered format so you can click through to the specific areas set out below. Alternatively, you can download a Pdf version
. Please also use the Glossary
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
1. Important information and who we are
App or browser-based training platform.
Our App and browser-based training platform are not intended for children and we do not knowingly collect
data relating to children.
policy we may provide on specific occasions when we are collecting or processing personal data about you
notices and privacy policies and is not intended to override them.
We have appointed a data privacy manager who is responsible for dealing with questions about our privacy
Contact details for Data Privacy Manager
manager in the following ways:
Full name of legal entity: VirtiHealth Ltd
Email address: firstname.lastname@example.org
Postal address: 1 Brassey Road, Old Potts Way, Shrewsbury, Shropshire, SY3 7FA
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK
regulator for data protection issues (www.ico.org.uk). We would appreciate the chance to deal with your
concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.2. The data we collect about you
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 collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data
includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data
includes billing address, delivery address, email address and telephone numbers.
- Financial Data
includes bank account and payment card details.
- Transaction Data
includes details about transactions with us.
- 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 this website.
- Profile Data
includes your username and password, your areas of professional and training interests, preferences, role title, feedback and survey responses.
- Usage Data
includes information about how you use our website, products and services .
- Marketing and Communications Data
includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data
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 provide our products and services to you.
In this case, we may have to cancel the supply of a product or service but we will notify you if this is the case at the time.3. How is your personal data collected?
We use different methods to collect data from and about you including through:
- Direct contact. You may give us your Identity and Contact Data by filling in forms on our App or
browser-based training platform or by corresponding with us. This includes personal data you
provide when you:
- register to use the App or browser-based training platform;
- create an account on our App or browser-based training platform;
- download or register the App;
- contact us to troubleshoot accessibility or useability within our App or browser-based training
- give us feedback or contact us.
- Automated technologies or interactions
. As you interact with our App or browser-based
training platform, we may automatically collect Technical Data about your use of the App or
browser-based training platform. We collect this personal data by using server logs and other
similar technologies.4. How we use your personal data
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 it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. For example, in connection with the provision of training services to you and disclosure about the use of those services by you under a contract with your employer or other institution with which you are associated.
- We may use your Identity, Contact and Usage to form a view on what we think you may want or
need, or what may be of interest to you and make recommendations of other relevant content.
- Where we need to comply with a legal obligation.
You have the right to withdraw consent to marketing at any time by contacting us at email@example.com.
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 also identified what our legitimate interests are where appropriate.
Note that we may process your personal data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer or user of our services and to install the App.
(a) Performance of a contract with you
(b) Necessary for our legitimate interests in delivering products and services to you
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(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 study how customers use our products/services)
To enable you to participate in a prize draw, competition or survey
(e)Marketing and Communications
Necessary for our legitimate interests (to study how our products/services are used, to develop them and grow our business)
To administer and protect our
business, the App and our
browser-based training platform (including troubleshooting, data analysis, testing, system maintenance, support, security reporting and hosting of data).
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content recommendations to you and measure or understand the effectiveness of our communications.
Necessary for our legitimate interests (to study how our products/services are used, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve
our 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 App and browser-based training platform updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you as a user of Virti products or services, about Virti products or services that may be of interest to you.
Necessary for our legitimate interests (to develop our products/services and grow our business)
To develop and test machine learning techniques to enable us to build features and improve our products and services
Necessary for our legitimate interests (to develop our products/services and grow our business)
To record your Profile Data
Necessary for our legitimate interests in ensuring we deliver the right training materials to you.
To record and analyse your usage of our training materials to provide reports to the organisation to which you are connected.
Necessary for our legitimate interests (to deliver our agreed products and services)
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product and service purchase, product and service experience or other transactions.
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 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.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary
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.
6. International transfers
We may share your personal data within the Virti Group. This may involve transferring your data outside the UK.
Also some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- We use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
7. Data security
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
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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting
requirements. We may retain your personal data for a longer period in the event of a complaint or if we
reasonably believe there is a prospect of litigation in respect to our relationship with you.
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.
For training users, we will retain personal data for a period of three months following the termination of the
contract with the organisation with which you are associated. This enables user to download relevant
analytical data for a short period. In some circumstances we will 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.
We will retain direct marketing personal data for a period of one year from last contact. We may write to you
towards the end of this period to determine whether you still wish to receive direct marketing
In some circumstances you can ask us to delete your data: see Your Legal Rights
below for further information.
9. Your legal rights
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 could 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 could 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.
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).
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 obligation
means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.11. THIRD PARTIES
Internal Third Parties
Other companies in the Virti Group acting as joint controllers or processors.
External Third Parties
Service providers acting as processors such as AWS and Hubspot based in multiple countries who provide IT customer relationship management and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK and US who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and US who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
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.
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 on 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:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
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.
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.