Privacy Policy
Voilo respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or use any of our mobile applications (Apps) or any services accessible though our website or Apps, and will tell you about your privacy rights and how the law protects you.
When installing any of our Apps, you consent to our processing of your personal data (including your name, contact details, financial and device information) as described in this policy for the purpose of operating the App. You may change your mind and withdraw consent at any time after installing an App by contacting us at info@voilo.co.uk, but that will not affect the lawfulness of any processing carried out before you withdraw your consent.
If you enable location-enabled services for our Apps in your settings, you consent to us processing your Location Data (including details of your current location disclosed by GPS or other technology) for the purpose of operating the App and providing services made available the App. You can disable location-enabled services for our Apps in your settings at any time, but that will not affect the lawfulness of any processing carried out before you disable these services.
This privacy policy is provided with the following numbered sections so you can easily find the specific areas set out below. You can find the policy on our website here . You can use the Glossary at the end to understand the meaning of some of the terms used in this privacy policy.
Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Voilo collects and processes your personal data through your use of our website or our Apps, including any data you may provide through our website or our Apps when you sign up to our newsletter or other updates, purchase a product or service, or take part in a competition.
Our website and our Apps are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide 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 other notices and privacy policies and is not intended to override them.
Controller
Contact details
Full name of legal entity: Voilo Limited, incorporated in England and Wales.
The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the relevant App or any of our services. Each time you wish to use our site or our Apps, please check these terms to ensure you understand the terms of the policy that apply at that time.
Third-party links
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 as follows:
We collect some of the information from the user as it is required for the app to function correctly. The information collected is as follows:
PERSONAL INFO:
Name: Required for the basic functionality of the app.
Email: Required for the basic functionality of the app.
Business Address: Required for the basic functionality of the app.
Phone Number: Required for the basic functionality of the app.
Financial INFO:
Bank Setup: Details we require are Bank Name, Account Holder Info, Sort Code and Account Number so that users with the role “Owner” can receive payments from customers via QR code.
Location INFO:
Approximate Location: Required for the basic functionality of the app.
Precise Location: Required for the basic functionality of the app.
Photos and Videos:
PHOTOS: To save and update user profile picture and business logo.
App Info:
Crash Analytics: When there is an unexpected occurrence of a crash in the app, then the relevant crash information is transmitted with the help of Firebase which the developer can view using the console of firebase.
App Interactions:
Using Firebase Analytics user events are collected at several points to collect relevant information about the app’s usage
Device ID:
The user’s device name and IP address are stored at the time of login for analytics purposes.
App Permissions:
Camera Permission: Needed for the user to update his profile picture and business logo.
Storage Permission: Needed so that the user can save the POS materials in pdf format on his device. They are also needed for the user to browse through the gallery and set a profile picture or business logo.
Fine and Coarse Location Permission: Needed so that the user’s location is available to the developer at the time of login. Location timestamps are needed for better account management.
- Identity Data : first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
- Contact Data : billing address, delivery address, email address and telephone numbers.
- Financial Data : bank account and payment card details.
- Transaction Data : includes details about payments to and from you and details of in-App purchases and other products and services you have purchased from us.
- Device Data: includes the internet protocol (IP) address, the type of 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 operating system and platform, your login data, the type of browser you use, time zone setting and location, browser plug-in types and versions, and other technology on the devices you use to access our website or use our Apps.
- Content Data: includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content, check-ins.
- Profile Data : includes your username and password, in-App purchase history and other purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data : includes details of your use of our website, Apps, products and services including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data : includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data : includes your current location disclosed by GPS or other technology.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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. However, 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.
How is your personal data collected?
- Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on our Apps or website, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Apps or our website, download or register an App, subscribe to any of our services or publications, search for an App or service, make an in-App purchase, apply for our products or services, purchase a supplier’s goods or services via an App, share data via an App’s social media functions, request marketing to be sent to you, enter a competition, promotion or survey, give us feedback, report a problem with an App, our services, or our website or otherwise contact us. If you contact us, we will keep a record of that correspondence.
- Information we collect about you and your device. Each time you visit our website or use one of our Apps we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies, server logs and and other similar technologies. We may also receive Device Data about you if you visit other websites employing our cookies Please see our cookie policy for further details.
- Location Data. We also use GPS or other technology to determine your current location. Some of our location-enabled services may require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
- Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Device Data from the following parties: analytics providers such as Google based outside the UK;
advertising networks based inside or outside the UK; and
search information providers based inside or outside the UK. - Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the UK;
- Identity and Contact Data from data brokers or aggregators based inside or the UK; and
- Identity and Contact Data from publicly available sources such as Companies House and the electoral register based inside the UK.
- Unique application numbers . When you want to install or uninstall a service containing a unique application number or when such a service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
How we use your personal data
- Where you have consented before the processing.
- 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 obligation.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To install an App and register you as a new App user |
Identity Contact Financial Device |
Your consent |
|
To register you as a new customer |
Identity Contact |
Performance of a contract with you |
|
To process in-App purchases and deliver services including managing payments, collecting money owed to us, confirming availability and making bookings with suppliers whose services are booked by customers using our booking services |
Identity Contact Financial Transaction Device Marketing and Communications Location |
Your consent Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
|
To manage our relationship with you including notifying you of changes to the App or any services, or to our terms or privacy policy, or asking you to leave a review or take a survey |
Identity Contact Financial Profile Marketing and Communications |
Your consent Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ services) Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions) |
|
To enable you to participate in a prize draw, competition or complete a survey |
Identity Contact Device Profile Usage Marketing and Communications |
Your consent Performance of a contract with you Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business) |
|
To administer and protect our business and our Apps and website, including troubleshooting, data analysis, system testing, system maintenance, support, reporting and hosting of data |
Identity Contact Device |
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) Necessary to comply with a legal obligation |
|
To deliver content and advertisements to you To make recommendations to you about goods or services which may interest you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App |
Identity Contact Device Content Profile Usage Marketing and Communications Location |
Consent Necessary for our legitimate interests (to develop our products/services, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website and Apps, products/services, marketing, customer relationships and experiences |
Device Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and Apps updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about goods or services that may be of interest to you |
Identity Contact Device Usage Profile Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you wish to understand more and make certain decisions about your personal data use, please contact: info@voilo.co.uk.
Promotional offers from us
We may use your Identity, Contact, Device, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time following the opt-out links on any marketing message sent to you or by contacting us at any time at info@voilo.co.uk .
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of an in-App or other product/service purchase, warranty registration, product/service experience or other transactions.
Cookies
We use cookies and other tracking technologies to distinguish you from other users of our Apps and our website and to remember your preferences. This helps us to provide you with a good experience when you use the Apps or browse our website and also allows us to improve our Apps and website. You can set your browser to refuse all or some browser cookies, or to alert you when website set or access cookies. If you disable or refuse cookies or other tracking technologies, please note that some parts of the website or Apps may become inaccessible or not function properly. For detailed information on the cookies and other tracking technologies we use, the purposes for which we use them and how you can exercise your choices regarding our use of them, 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.
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.
Disclosures of your personal data
- Internal Third Parties as set out in the Glossary (Section 10).
- External Third Parties as set out in the Glossary (Section 10), including the following:
- Bitbucket
- Google (Firebase)
- Twilio (Sendgrid)
- Finexer (Payment service provider)
- UK Charities (to apply Gift Aid in relation to any donation you make using our Apps).
- 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.
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 will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Data security
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.
All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using secured sockets layer (SSL) or transport layer security (TSL) technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Apps or website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We will collect and store personal data on your Device using application data caches and browser web storage (including HTML5) and other technology.
Certain services may include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
Data retention
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights (Section 9) below for further information.
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.
In the event that you do not use an App for a period of one year then we will treat the account as expired and your personal data may be deleted.
Your legal 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.
Glossary
LAWFUL BASIS
Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
If other companies join Voilo in a single group, we will clarify whether they will act as joint controllers or processors, where they are based and what services they may provide to you.
External Third Parties
- Market research service providers, fraud prevention agencies, and promotional and advertising companies based inside or outside the UK.
- Service providers acting as processors based inside or outside the UK who provide IT and system administration services to Voilo.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based inside or outside the UK who provide consultancy, banking, legal, insurance and/or accounting services.
- HM Revenue & Customs, 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
Under certain circumstances you have the following rights under data protection laws in relation to your personal data:
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 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.
Request 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 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.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at info@voilo.co.uk.