Privacy policy

Introduction

1.1 Important information and who we are

Welcome to Valla Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).

At Valla Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Customers
• Suppliers
• Business contacts
• Employees/Staff Members
• Third parties connected to your customers

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees, contractors and staff members and all Personal Data processed at any time by us.

1.2 Who is Your Data Controller and Data Protection Officer

Valla Ltd is your Data Controller and responsible for your Personal Data.

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

Full name: Danae Shell
Email address: hello@valla.uk
Postal address: 6th Floor Gordon Chambers, 90 Mitchell Street, Glasgow, Scotland, G1 3NQ

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.

1.3 Processing data on behalf of a controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees and contractors who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
• Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
• Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
• Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
• Maintain a record of all categories of processing activities carried out on behalf of a Controller;
• Cooperate, on request, with the supervisory authority in the performance of its tasks;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
• Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority; and
• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain their expert knowledge;

Legal basis for data collection

2.1 Types of data / privacy policy scope

“Personal Data” 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
• Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
• Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
• Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
• Financial Data: These are your banking details e.g. your account number and sort code.
• Transactional Data: This is information of details and records of all payments you have made for our services or products.
• Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
• Customer Support Data: This includes feedback and survey responses.
• Usage Data: information about how you use our website, products and services.
• Employer's data: details of your employer/ex-employer and personal data of staff and other individuals connected to your employer
• Your data: any data that you upload or submit to the Valla platform, including the contents of any documents uploaded
• Any other correspondence: any correspondence or any other information that you choose to send to us at Valla, whether by email, through our inbuilt online chat service, or otherwise
• Anonymised data which does not identify you: for example, the times and dates of your use of the Valla platform, your operating system and internet browser, the clicks taken to reach the Valla platform and your computer's IP address

We also collect, use and share Aggregated Data such as seeing what percentage of users continue to use the Valla platform following a set timeframe after the initial sign-up. 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. 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 may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

For the purposes of our business we also collect what is known under the GDPR as special categories of Personal Data. We collect the following types of special Personal Data:

• Political Data: Information about race, or ethnicity, religious beliefs, sexual orientation and political opinions
• Trade Union Membership Data
• Health Data: Information about health, including any medical condition, health and sickness records
• Information about criminal convictions and offences

In order to collect this special kind of data we need enhanced legal justifications beyond the ordinary legal justifications under the GDPR. We explain which justifications we rely on in paragraph 2.2 below.

2.2 The legal basis for collecting that data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

• “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
• “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

For the special categories of data that we collect, the enhanced legal justification we rely on is:

(a) the data subject has given explicit consent to the processing of such Personal Data for one or more specified purposes (“Explicit Consent”)

How we use your personal data

3.1 Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.