IBS VP Limited and https://ibsvp.co.uk (and all subdomains)
PRIVACY & COOKIES POLICY
We understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, https://ibsvp.co.uk/ and subdomains (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
|“Account”||means an account required to access and/or use certain areas and features of Our Site.|
|“Cookies”||means a small text or other file placed on your computer by Our Site when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the Cookies and/or JWT used by this Website are set out in Part 14, below.|
|“Cookie Law”||means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011; and all/any applicable law covering the use of JSON Wen Tokens (“JWT).|
|“User / Users”||means any third party that accesses, browses, crawls, scrapes, or in any way uses Our Site and is not employed by The Company and acting in the course of their employment.|
|“Website / Our Site”||means the website that you are currently using and any sub-domains of this site including all/any mobile applications (Apps) that link to or reference these Terms unless expressly excluded by their own terms and conditions.|
- Information About Us
The names ‘IBS VP’ and ‘ibsvp.co.uk’ are trading names of IBS VP Limited., a Company incorporated in England and Wales under Company No. 03376738 with Registered address at 32 Addison Grove London W4 1ER. Our Site is owned and operated by IBS VP Limited.
Our Data Protection Officer may be contacted by email at firstname.lastname@example.org
- What Does this Policy Cover?
- What is Personal Data?
Personal data is defined by the Data Protection Act 2018 as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
Under the Data Protection Act 2018, you have the following rights, which we will always work to uphold:
- b)The right to access the personal data we hold about you. Part 13 will tell you how to do this.
- c)The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
- d)The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 15 to find out more.
- e)The right to restrict (i.e. prevent) the processing of your personal data.
- f)The right to object to us using your personal data for a particular purpose or purposes.
- g)The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- h)Rights relating to automated decision-making and profiling. we do not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 15.
Further information about your rights can also be obtained from the Information Commissioner’s Office (https://ico.org.uk/) or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- What Data Do We Collect?
- Date of birth;
- Email address;
- Telephone number;
- Business name;
- Job title;
- Dates of intended travel;
- Places of intended travel;
- Personal preferences when travelling;
- Passport details (number, issuing authority, date of issue, date of expiry);
- Payment information;
- Home address;
- Work address;
- Information about your preferences and interests;
- Other information as required for the purpose of visa processing;
- IP address;
- Web browser type and version;
- Operating system;
- A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
- How Do You Use My Personal Data?
Under the Data Protection Act 2018, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data will be used for the following purposes:
- Providing and managing your Account;
- Processing visas and/or providing other travel services;
- Providing and managing your access to Our Site;
- Personalising and tailoring your experience on Our Site;
- Supplying our products and/or services to you. Your personal details are required in order for us to enter into a contract with you.
- Personalising and tailoring our products and/or services for you.
- Communicating with you. This may include responding to emails or calls from you.
- For delivery
- Supplying you with information by email and/or post that you have opted in to (you may unsubscribe or opt out at any time by emailing our Data Protection Officer email at: email@example.com asking to unsubscribe or opt out).
- Analysing your use of Our Site and gathering feedback to enable us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Act 2018 and the Privacy and applicable law including Cookie Law, and you will always have the opportunity to opt out.
Third Parties (including whose content appears on Our Site) may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We may use automated systems for carrying out certain kinds of automated decision-making and/or automated profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Act 2018 gives you the right to do so. Please contact us to find out more using the details in Part 15.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected (unless requested by you to keep your personal data for future travel arrangements for an unlimited period). The following factors will be used to determine how long it is kept:
- We will regularly review the personal data we hold, and delete anything we consider is no longer needed.
- If/when establishing any standard retention periods for different categories of information, we will take account of any professional rules or regulatory requirements that apply.
- We will from time to time conduct an audit to check through the records we hold to make sure we are not holding on to personal data for too long, or deleting it prematurely.
- Personal data will need to be retained for longer in some cases than in others.
- How and Where Do You Store or Transfer My Personal Data?
Please contact us using the details below in Part 15 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.
- Do You Share My Personal Data?
We will not share any of your personal data with any third parties subject to the following exceptions:
We may share the personal information with third parties for the following purposes:
To complete your visa, document legalisation, or process request as necessary to provide visa and immigration services to you and your family, including disclosure to government agencies in the form of applications, photographs, and petitions for visa requests and/or immigration benefits. This may include providing sensitive data required for an immigration process request to Visa Application Centres, Logistics Companies, Invitation Providers and/or Translators/Solicitors.
As required by law in response to requests by public authorities including meeting national security or law enforcement requirements.
If we ever need to share your data with third parties, e.g. for payment processing or other necessary reasons, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if for example we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
- How Can I Control My Personal Data?
11.1 In addition to your rights under the Data Protection Act 2018, when you submit personal data via Our Site, you may be given options to restrict our use of your personal data. In particular, we aim to give you control over our use of your data for direct marketing purposes (including the ability to opt out of receiving emails from us, which you may do by unsubscribing using the links provided in our emails and/or at the point of providing your details and by managing your Account, if applicable).
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
- Can I Withhold Information?
You may access certain areas of Our Site without providing any personal data at all. However, to use all features and functions available on Our Site or to use the services we provide, you will be required to submit or allow for the collection of certain data.
- How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. When making a Subject Access Request, you should tell us everything we need to know to respond to your request as quickly as possible.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests), a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 28 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on Our Site for visitor analytics and for supplying third party widgets like weather widget and othes. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up or prompt requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however, certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Further information about “strictly necessary” Cookies can be obtained by request using the contact details provided in Part 15. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
Our Site uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Site is used. This, in turn, enables us to improve Our Site and the products and/or services offered through it.
The analytics service(s) used by Our Site use(s) the following Cookies:
Google Analytics relies on cookies to ‘remember’ and record a users’ interaction on a website. In this blog post, I am going to look at each of the specific cookies Google Analytics uses, the potential customisations and a way of using Google Debugger to see the cookie data.
Google Analytics uses a set of up to 4 cookies – _utma, _utmb, _utmz and _utmv – via the ga.js library to record information about what a user has seen or done on a particular page. It sets these cookies at the domain specified in the document.host browser property and with the root level path.
It is important to remember that cookies are browser-specific when it comes to ga.js. Therefore, a user with Google Chrome on their work computer will have different cookies stored than if they are using Google Chrome on their home computer.
Google Analytics Cookie Types
This cookie is used to determine new and returning visitors. It has an expiration time of 2 years. If the ga.js library is executed and no _utma cookie exists, this will be recorded as the user’s first visit and a _utma cookie will be set. If a _utma cookie is already in place, the expiration time is reset and the user is recorded as a return visitor.
This cookie is used to determine a new session. The cookie is set when the ga.js library executes and there is no _utmb cookie in place. It has an expiration time of 30 minutes, therefore if a user is inactive for a period longer than this, a new cookie will be set when the library executes and the interaction will be recorded as a new session.
This cookie is used for storing visitor-level custom variable data. It is created when the _setCustomVar method is used with a visitor level custom variable. Like the _utma cookie, this cookie expires after 2 years and is reset each time the user visits a site before the expiration of the cookie.
Although each of these cookies has a set expiration time, each time the ga.js library is executed and the expiration time has not been met, the cookie is updated, resetting the expiration date to its original value.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
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 including, but not limited to, login and personalisation settings.
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.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details
For the attention of the Data Protection Officer
Postal Address: IBS VP Limited, 202 Kensington Church Street, London, W8 4DP
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
- Terms & Conditions
Use of Our Site is governed by our Terms & Conditions, and this Privacy & Cookies Policy has been incorporated into the said Terms & Conditions by reference. This Privacy & Cookies Policy should be read in conjunction with the said Terms and Conditions. Click here to view the Terms & Conditions