Privacy policy & cookies

Data controller

Vortexa Limited is a company registered in England, UK under company number 09966213 whose registered office is at Portsoken House, 155-157 Minories, London, England, EC3N 1LJ  United Kingdom.

Vortexa Limited is registered with the UK Information Commissioner’s Office (ICO) with registration number ZA694747

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

Contact details

Our full details are:

Full name of data controller legal entity: Vortexa Limited

FAO Data Protection Officer

Email address: DPO@Vortexa.com

Postal address: Portsoken House, 155-157 Minories, London, England, EC3N 1LJ  United Kingdom

Telephone number: + 44 (0)  20 3972 2212

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 consider that the ICO would also be the lead supervisory authority for Vortexa since the UK is the place of the majority of our operations. For data protection issues in other countries, you have the right to complain at any time to the supervisory authority for that country.

We would always prefer that you come to us to help address any concerns of a privacy nature before you go to the ICO or other applicable supervisory authority, so please contact us in the first instance.

We may ask you to provide Personal Information when you:

• Use our websites or application/s;
• Request quotes, services, support, downloads, trials, whitepapers, training or information;
• Place orders for products or services or register for or attend events, meetings or webinars;
• Create and manage an account;
• Participate in surveys or other promotional activities online or in any other venue;
• Provide a testimonial;
• Subscribe to newsletters, Vortexa whitepapers, marketing and promotional emails or other materials;
• Careers; job applications, background searches
• Interact with us on third party social networks (subject to that third party’s terms of use and privacy policies); or
• Contact us.

Categories of Personal Information we collect may include your name, email address, home address, contact telephone numbers, user IDs and passwords. It may also include work information such as job title and other business or company information. We may also collect demographic information, such as your age, gender, interests, and preferences. Forms that you choose to complete will indicate whether information requested is mandatory or voluntary. If you make a purchase, we may ask for billing information.

In order to offer you a more consistent and personalised experience in your interactions with Vortexa, information collected through one source may be combined with information Vortexa obtains through other sources. This may include information that allows us to identify you across multiple devices through which you access our websites. We may also supplement the information we collect with information obtained from other parties, including our Business Partners and other third parties to create customised profiles about you. Examples of how we may use this information include using your data to help us to improve your experience using our website, to present you with options tailored to your preferences and for targeted advertising purposes as explained below.

If you wish to withdraw your consent at any time, you can contact us at DPO@Vortexa.com

Some Vortexa services may be co-branded and offered in conjunction with another company. If you register for or use such services, both Vortexa and the other company may receive information collected in conjunction with the co-branded services, and may use the information according to each company’s privacy statement and other agreements with you.

Information We Automatically Collect

We may automatically collect behavioural and usage information about your visits to our websites, including the pages you view, the links and advertisements you click, search terms you enter, and other actions you take in connection with Vortexa websites and services. We may also collect certain information from the browser you use to come to our website, such as your IP address, device identifier, location data browser type and language, access times, the Uniform Resource Locator (URL) of the website that referred you to our website and the URL to which you browse away from our site if you click on a link on our site.

Information from Third Party Sources

We may obtain information about you from third party sources such as public databases, our Business Partners, joint marketing partners, social media platforms, and from other third parties. Examples of the information we may receive from other sources include: page-view information from some business partners with which we operate co-branded services or joint offerings. We may use the information to better understand you to enhance our ability to provide relevant marketing, products and services to you. If the information contains Personal Information, we will take steps to ensure that the Personal Information passed to us has been obtained in compliance with applicable data protection laws and is legally capable of being transferred to us.

We will only use your personal information when the law allows us to. Vortexa may use your Personal Information to

• Deliver the products, solutions, services and support you have requested;
• Send communications to you, including information about our product, including notifications about our products and services, specific Vortexa programmes in which you have chosen to participate, products, solutions and services available from Vortexa, events, promotional offers and surveys;
• Facilitate your use of our website, online Vortexa chat forums, including Vortexa news, whitepapers, research, podcasts and blogs;
• Offer Live Chat assistance to respond to your online enquiries;
• Facilitate communications from Vortexa Business Partners;
• Customise, analyse and improve our products, solutions, services (including the content and advertisements on our website to identify usage trends or determine the effectiveness of our marketing campaigns), technologies, communications and relationship with you;
• Better understand our customers and online users, including profiling based on interests and interactions with our site;
• Personalise content and implement your preferences;
• Enforce our conditions of sale, website terms and separate contracts (if applicable) with you;
• Prevent fraud and other prohibited or illegal activities;
• Protect the security or integrity of our websites, our businesses, and our products or services; or
• Perform other functions or serve other purposes, as disclosed to you at the point of collection, or as required or permitted by law.

Legal Basis of Processing

Our legal basis for collecting and using your Personal Information as described in this Privacy Policy will depend on the Personal Information concerned and the specific context in which we collect it. In general, we collect and process your Personal Information on one or more of the following bases:

• Your consent, for example where we have obtained your consent to process your personal data for certain activities (such as the use of cookies for online tracking and analysis). You are free to withdraw your consent at any time by contacting DPO@Vortexa.com If you withdraw your consent, it will not affect the lawfulness of any processing based on your consent before you withdrew it. Where applicable, we may ask for your consent to processing at the point where you provide your Personal Information.
• To comply with a contractual obligation (for example, using your details for invoicing where you have bought a product from us or using your personal details where you have asked us to do something before making a purchase, such as providing you with a quote).
• For compliance with Vortexa’s legal obligations where other laws require the processing of your personal information (for example, health and safety, taxation and anti-money laundering laws) or where we need your personal information to protect your vital interests or those of another person.
• Vortexa’s (and its Business Partners’) legitimate interests which include the provision of this website and/or relevant products and services, and/or the carrying out of marketing and profiling activities, provided always that our legitimate interests are not outweighed by any prejudice or harm your rights and freedoms.

If you have any questions or need more information concerning the legal basis on which we collect your Personal Information, please contact us at DPO@Vortexa.com.

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

Retention of Your Data

We will retain your Personal Information as necessary in connection with the purposes described in this Privacy Policy, for as long as your account is active, and in accordance with Vortexa’s retention policies and applicable law.

We assess the appropriate retention period for different Personal Information based on the size, volume, nature, and sensitivity of that Personal Information, the potential risk of harm to you from unauthorised use or disclosure of that Personal Information, the purposes for which we are using that Personal Information, applicable legal requirements for holding that Personal Information, and whether we can achieve those purpose(s) through other means.

International Transfers

Vortexa may transfer your Personal Information to other companies within the Vortexa group and/or to its Business Partners, if required for the purposes described in this Privacy Policy. This may involve the transfer of your Personal Information to countries outside your home country or region, including outside the European Economic Area if that is your region, which may have a different level of data protection from your home country. Such countries may Include, without limitation, the United States, Singapore and other countries in which Vortexa or its subsidiaries, affiliates or Business Partners maintain facilities. In order to provide adequate protection for the transfer of your Personal Information, we ensure that we comply with applicable data protection laws for transfer of Personal Information including standard contractual clauses and other arrangements (as appropriate) with our subsidiaries, affiliates and Business Partners in respect of such transfers. We will take all reasonable technical and organisational measures to safeguard Personal Information we transfer and ensure they also have the same in place.

We may share your Personal Information with Vortexa subsidiaries or Business Partners for the purposes described in this Privacy Policy, Including (without limitation) to carry out transactions you request, or to make our business (or that of our subsidiaries) more responsive to your needs. Our subsidiaries and/or Business Partners may contact you with information about Vortexa, and Vortexa-branded products, services or offers. We will only share your Personal Information with Vortexa subsidiaries and Business Partners who agree to protect your Personal Information and use it solely for the purposes specified by Vortexa.

In addition, Vortexa may share your Personal Information with participants in our sales and marketing chain, including but not limited to retailers, resellers, distributors, integrators, order fulfillers and some sales agents and channel partners, for the limited purposes of selling, marketing or providing support for Vortexa products and services.

We may disclose your Personal Information for any purpose with your consent.

We may also disclose your Personal Information in connection with law enforcement, fraud prevention or other legal action; as required by law or regulation; if Vortexa (or a part of Vortexa) is sold or merges with another company; or if Vortexa reasonably believes it is necessary to protect Vortexa, its customers or the public.

Except as described above, we will not disclose your Personal Information to third parties for their own marketing purposes without your consent.

Where the processing of your Personal Information is subject to UK and EU data protection laws, you have the following data subject rights. Please note that these rights are not absolute and in certain cases are subject to conditions as specified in applicable law:

• Access:you have the right to request information about how we process your Personal Information and to obtain a copy of that Personal Information.
• Rectification:you have the right to request the rectification of inaccurate Personal Information about you and for any incomplete Personal Information about you to be completed.
• Objection:you have the right to object to the processing of your Personal Information, which is based on our legitimate interests (as described above).
• Erasure:you have the right to request the erasure of your Personal Information (subject to certain conditions).
• Automated decision-making:you have the right not to have a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.
• Restriction:you have the right to ask us to restrict our processing of your Personal Information, so that we no longer process that information until the restriction is lifted.
• Portability:you have the right to receive your Personal Information, which you have provided to us, in a structured, commonly used and machine-readable format and to have that information transmitted to another organization in certain circumstances.

In addition to the above, you have the right to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Information infringes applicable data protection law.

If you have any questions about the type of Personal Information we hold about you or if you wish to request deletion or correction of Personal Information we hold about you, or exercise any other data subject right, please send a written request to DPO@Vortexa.com or to the postal address provided in this Privacy Policy. While we will make reasonable efforts to accommodate your request within 30 days (or the maximum allowed by law), we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.  We will be obligated to confirm your identity before any Data Subject Access request is completed.

You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

You may choose to receive or not receive marketing communications from Vortexa by indicating your preferences. Opportunities to select your preferences Include the following:

• You can click “unsubscribe” in any marketing email communications we send you, or by sending us an email at DPO@Vortexa.com;
• You can email us at DPO@Vortexa.com or write to us at DPO, Vortexa Ltd, Portsoken House, 155 Minories, London EC3N 1LJ to withdraw your consent.

Any marketing by Vortexa, or any third parties on behalf of Vortexa, will be conducted in accordance with applicable laws and Include (where applicable) methods to allow you to express your preferences (including the possibility of being removed from our advertising and marketing lists as set out above).

Please allow up to 10 business days for your email preferences to take effect. As some promotions are developed in advance, you may sometimes receive marketing communications after we receive your preference request. If you withdraw your consent for receiving marketing communications, we may still communicate with you in connection with transactions you request and/or service-related matters.

Vortexa takes all reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. The ways we do this Include:

• Limiting physical access to our premises;
• Limiting access to the information we collect about you;
• Ensuring that we and our Business Partners have appropriate security safeguards to keep Personal Information secure; and
• Where required by law, destroying or de-identifying Personal Information.

We encourage you to keep any passwords you use confidential and to be careful to avoid “phishing” scams where someone may send you an email that appears to be from Vortexa asking for your personal information. Vortexa will not request your ID or password through email.

Vortexa takes children’s privacy seriously. We do not knowingly collect personal information from children through our websites and our services are not sold or marketed to children. If you are a child as understood by laws of your country, please do not submit any Personal Information through our websites without the express consent and participation of a parent or guardian.

Vortexa websites uses “cookies” to enable you to sign in to our services and to help personalise your online experience. These technologies and the information collected about you may be used to track your activity across multiple devices. Where appropriate, we use cookies to store your preferences and other information on your computer in order to save you time by eliminating the need to enter the same information repeatedly.

A cookie is a piece of text that is placed on your computer’s hard drive. Depending on the settings you have selected, your browser adds the text to your device as a small file. Many browsers are set to accept cookies by default. You can accept or decline cookies as you prefer. The Help portion of your web browser, most likely found on the toolbar, typically tells you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

Cookies allow you to take advantage of some of Vortexa’s essential features, including allowing you to save a Shopping Cart and remembering items in your Shopping Cart between visits. If you choose to decline cookies, you may not be able to sign in or use other interactive features of Vortexa websites and services that depend on cookies.

Targeted Display Advertising by Vortexa and Others

Vortexa also works with advertising and personalisation Business Partners to use cookies, and internet browsing to help us display personalised content and appropriate advertising during your visits to mobile applications, Vortexa.com and other websites. For example, if you view a product on the Vortexa website, you may see offers for similar products on other websites you visit. Cookies placed by these Business Partners also assist us with measuring the performance of our advertising campaigns and with identifying the pages you view, the links and ads you click on, other actions you take on those web pages, and the site from which you came before arriving at a web page. These cookies can be effective whether you are on Vortexa.com or another website. If you opt out of receiving targeted display advertising, the data associated with these cookies will not be used.

“Do Not Track” Signals

Please note that while you may have the opportunity to opt-out of targeted advertising you may be able to control the use of cookies through your web browser as described in the “How We and Our Partners Use Cookies” section above, some web browsers may also give you the ability to enable a “do not track” setting. This setting sends a special signal to the websites you encounter while web browsing. This “do not track” signal is different from disabling certain forms of tracking by declining cookies in your browser settings, as browsers with the “do not track” setting enabled still have the ability to accept cookies. Vortexa does not respond to web browser “do not track” signals at this time. If we do so in the future, we will describe how we do so in this Privacy Statement. For more information about “do not track,” visit www.allaboutdnt.org.

Targeted Email Marketing by Vortexa

Some marketing you receive, including email marketing, may also be personalised based on your visits to Vortexa.com and your browsing and purchase history. In addition, when you click on some links in email marketing you receive, our email service provider may place a cookie on your browser. This type of cookie would be linked to your email address or IP address and used to gather information about the products and services you view and purchase on Vortexa.com. Information gathered may be used to personalise and customise future email marketing messages you receive. You may opt out of this use by clicking on the unsubscribe link provided in every personalised email marketing message you receive.

How We and Our Partners Use Web Beacons, Pixel Tags and Tracking Technology

Vortexa or its Business Partners may use web beacons on our websites, in our email messages, in our advertisements on other websites, or in our advertisements in others’ email messages. Similarly, third parties whose content or advertisements appear at Vortexa.com, or whose email messages Vortexa.com sends to our users, may also place web beacons in their advertisements or email messages for the purposes of measuring the effectiveness of the content, advertisements or email messages.

A web beacon is an electronic image that can be used to recognise a cookie on your computer when you view a web page or email message. Web beacons help us measure the effectiveness of our website and our advertising in various ways. For example, web beacons may count the number of individuals who visit our website from a particular advertisement or who make a purchase from our website after viewing a particular advertisement or they may tell us when a web page is viewed and provide a description of the page where the web beacon is placed. Web beacons may also measure the effectiveness of our email campaigns, by counting the number of individuals who open or act upon an email message, determining when an email message is opened and determining how many times an email message is forwarded. Subject to local laws, we may combine the information that we collect through web beacons with other Personal Information we have collected from you.

We may allow some of our Business Partners to compile individual or aggregated statistics from the use of web beacons on Vortexa.com by Vortexa, its agents or others, to determine the effectiveness of online marketing and to develop statistics on how often clicking on an advertisement results in a purchase or other action on the advertiser’s site. Aggregate information may Include demographic and usage information. No Personal Information about you is shared with Business Partners for this research.

You can make some web beacons unusable by rejecting cookies in your web browser as described in the How We and Our Partners Use Cookies section above.

When you visit our websites or view one of our email messages, we may use pixel tags (also called “clear” gifs), tracking links and/or similar technology to note some of the pages you visit on our websites. We may also use pixel tags to determine what types of email your browser supports. We may use the information collected through web beacons, pixel tags, tracking links and similar technology in combination with your Personal Information to personalise your experience on Vortexa.com and to provide you with more useful and relevant advertisements.

Our website may include social media features, including Facebook “Like” button and Twitter “Follow” button. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing them.

Please be aware that Vortexa provides links to other websites, which if you click on them may collect Personal Information about you. The information practices of those third-party websites linked to Vortexa.com are not covered by this Privacy Statement.

We will occasionally update this Privacy Statement. If we make changes to this Privacy Statement or make any material changes to how we use your Personal Information, we will revise this Privacy Statement to reflect such changes. We encourage you to periodically review this Privacy Statement to be informed of how we are using an protecting your Personal Information.

If you would like to contact us for any reason regarding our privacy practices, please email us at DPO@Vortexa.com or write to us at the following address:

Right to complain

You have a right to make a complaint if you wish to do so. The organisation with oversight of our processing is the Information Commissioner’s Office, which can be contacted in writing at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, by telephone (0303 123 1113) or by e-mail (casework@ico.org.uk).

Changes to this privacy policy

We may change, modify, add or remove portions of this Privacy Policy at any time, and any changes will become effective immediately.

Any changes we make to our Privacy Policy will be posted on this page and, where appropriate, notified to you.