Website Privacy Policy

BACKGROUND:

Vault IP Limited understands 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, www.vault-ip.com (“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.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of Our Site. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. 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;
“Cookie”	means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 200

2. Information About Us

Our Site is owned and operated by Vault IP Limited, a limited company registered in England under company number 09143739.

Registered address and Main trading address: 5^th Floor, Cavendish House, Waterloo Street, Birmingham, England, B2 5PP.

VAT number: 199 5824 40.

Data Protection Compliance Manager: Michelle Bishton.

Email address: admin@vault-ip.com

Telephone number: 0121 296 9164.

Postal address: 5^th Floor, Cavendish House, Waterloo Street, Birmingham, England, B2 5PP.

We are regulated by IPReg.

We are a member of IPReg, Chartered Institute of Patent Attorneys (CIPA), Chartered Institute of Trademark Attorneys (CITMA) and the European Patent Institute (EPI).

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4. What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) 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.

5. What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about Our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.

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 hold. 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 withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) 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.

i) 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.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office 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.

We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.

6. What Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about Our use of Cookies and similar technologies and Our Cookie Policy. We do not collect any ‘special category’ or ‘sensitive’ personal data relating to children or data relating to criminal convictions and/or offences.

Data Collected	How we Collect the Data
Identity Information including Name – Title / First Name / Last Name.	Your First and Last Name will be populated into our website by you when contacting us for information or opt-ing in to receive marketing communication from Us. Alternatively, if you call to speak with us, we will ask you for your First and Last name. Your title will be presumed based on your name unless you specifically state it to us otherwise.
Contact information including mailing address, email address and telephone number (mobile or office number).	You will be required to provide us your contact information (i.e. email address and telephone number) when you have a query so that we have a means to respond to you. Your mailing address will be collected at a later time by a member of staff (if required).
Business information including business name, job title, industry and size of the organisation.	We will speak with you directly to understand your business and role within your organisation. We will keep this on file for future reference when addressing you at your company.
Data from third parties including the Lead source of how you were referred to our organisation, as well as a LinkedIn profile link which will include a tick box showing if we have connected on LinkedIn.	We will always ask in what way you were referred to our organisation as a means of understanding how our business is reaching potential clients. This information is manually inputted into our CRM database by a member of staff.
General communication through a web form including a subject line and message box.	Our website contains a contact us page that allows you to populate a message to us with free text. Any information that you provide in the subject line and message box will be collected and stored appropriately in order to respond and/or provide our services to you.

7. How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and Our lawful bases for doing so:

What we Do	What Data we Use	Our Lawful Basis
Registering your details on Our Site and communicating with you.	First and last name, contact information such as email address and telephone number.	We require this data in order to conduct business with you and communicate with you in a professional manner.
Supplying services to you.	First and last name, contact information such as business name, postal address, email address and telephone number.	We require this specific data for contractual necessities when entering into a service agreement with you.
Supplying you with marketing information by email and/or post, that you have opted-in to (you may opt-out at any time by clicking the opt-out link on our emails).	First and last name, email address and/or postal address.	In order to stay compliant with our legal obligation under GDPR, we need you to provide us with specific instructions that you are happy for us to contact you.

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 and/or post with information, news, and offers on Our 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 Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights

8. 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. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long we Keep It
Identity Information including first and last name.	We will aim to review the records we hold on a six-yearly basis for the purposes of case files for patents and/or trademarks. See the following gov.uk link for further information on the retention and disposal of patent and trademark related records: https://www.gov.uk/government/publications/retention-and-disposal-policy-for-patent-and-trade-mark-related-records If you opt-out of our marketing communications being sent to you, your details will be added to a non-solicitation blacklist with immediate effect to ensure you don’t receive any further communication. We will continue to keep your details as long as you are happy to continue receiving marketing communication from us OR for as long as you are a client with a patent or trademark case on file.
Contact information including email address and telephone number.
Business information including business name and job title.

9. How and Where Do You Store or Transfer My Personal Data?

We may store or transfer some or all of your personal data in countries that are not part of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We share your data with external third parties, as detailed below in Part 10, that are based outside of the EEA. The following safeguards are applied to such transfers:

We will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission. More information is available from the European Commission .

We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission .

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission .

Please contact us using the details below in Part 15 for further information about the particular data protection mechanisms used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

· limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

· procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

10. Do You Share My Personal Data?

If we sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may sometimes contract with the following third parties to supply certain services.

Recipient	Activity Carried Out	Sector	Location
Insightly CRM (Data Processor).	CRM system for generating & storing sales information, customer information, projects, and integration to other IT platforms we use as a business i.e. website.	IT and Marketing	Insightly Inc. 680 Folsom, Ste. #550 San Francisco, CA 94107 USA
Mailchimp (Data Processor)	Online Marketing platform	Marketing and IT	Operated by The Rocket Science Group LLC, a company headquartered in the State of Georgia in the United States.
Xero (Data Controller)	Cloud Accounting Software	Accounting and IT	Head Office: XERO ONE, 19-23 Taranaki St, Te Aro, Wellington, 6011. Xero (UK) Limited (company number 06071722) is our representative in the European Union.
Microsoft Office 365 (SharePoint) (used for Data Processing)	Online technology service offering email, calendar, file sharing & collaboration tools	IT	Microsoft Office 365 tenants are defaulted to a data centre geography (Geo) based on the country of the transaction associated with that tenant’s first subscription. Exchange, SharePoint & Skype for Business is located in Europe. Microsoft teams are located in the United Kingdom.
Equinox (Data Controller)	IP Management Software for case management	IT	Work AnyWare Ltd. Carlton House, 3-5 Alma Road, Leeds, United Kingdom LS6 2AH

If any of your personal data is shared with a third party, as described above, 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.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

11. How Can I Control My Personal Data?

11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, 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 strong controls on 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 at the point of providing your details).

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.

12. Can I Withhold Information?

You may access Our Site without providing any personal data at all.

You may restrict Our use of Cookies. For more information, see Part 14 and Our Cookie Policy.

13. 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.

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 14 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.

14. How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

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 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.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. 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.

The following first-party Cookies may be placed on your computer or device:

Name of Cookie	Purpose	Strictly Necessary
p.gif	Statistic cookie to help us understand how visitors interact with our website by collecting and reporting information anonymously.	YES
crumb	Prevents cross-site request forgery (CSRF). CSRF is an attack vector that tricks a browser into taking unwanted action in an application when someone’s logged in.	YES
test	Investigates if the browser supports cookies and prevents errors.	YES

Our Site uses analytics services provided by Squarespace Analytics and Google Analytics. 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 services offered through it.

The analytics service(s) used by Our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie	First / Third Party	Provider	Purpose
_ga	Third	Google Analytics	Used to distinguish users. Collects information on site activity, including which pages you have visited and what browser and operating system you are using, allowing us to improve our website. Expires after 2 years.
_gid	Third		Used to distinguish users. Expires after 24 hours.
_gat	Third		Used to throttle request rate. If Google Analytics is deployed via Google Tag Manager, this cookie will be named _dc_gtm_<property-id>. Expires after 1 minute.
AMP_TOKEN	Third		Contains a token that can be used to retrieve a Client ID from AMP Client ID service. Other possible values indicate opt-out, in-flight request or an error retrieving a Client ID from AMP Client ID service. Expires after 30 seconds to 1 year.
_gac_<property-id>	Third	Google Analytics	Contains campaign related information for the user. Expires after 90 days
ss_cid	Third	Squarespace Analytics	Identifies unique visitors and tracks a visitor’s sessions on a site. Expires after 2 years.
ss_cvr	Third		Identifies unique visitors and tracks a visitor’s sessions on a site. Expires after 2 years.
ss_cvisit	Third		Identifies unique visitors and tracks a visitor’s sessions on a site. Expires after 30 minutes.
ss_cvt	Third		Identifies unique visitors and tracks a visitor’s sessions on a site. Expires after 30 minutes.
ss_cpvisit	Third		Identifies unique visitors and tracks a visitor’s sessions on a site. Expires after 2 years.
ss_cookieAllowed	Third		Remembers if a visitor agreed to placing Analytics cookies on their browser if a site is restricting the placement of cookies. Expires after 30 days.

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.

15. 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 Michelle Bishton):

Email address: admin@vault-ip.com .

Telephone number: 0121 296 9164.

Postal Address: 5^th Floor, Cavendish House, Waterloo Street, Birmingham, England, B2 5PP.

16. Changes to this Privacy Policy

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.

Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site following the alterations. We recommend that you check this page regularly to keep up-to-date.

This Privacy Policy was last updated on 12^th October 2018.

You can download a copy of our Website Privacy Policy here.