Last update: 2 June 2018
VASTCLICKS is committed to protecting and respecting your privacy. We use the information we collect about you to provide you with the Services contained in our App and websites located at www.vastclicks.com and other associated URLs displaying this privacy statement owned by Adidit Limited.
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4 In this policy, “we”, “us” and “our” refer to VASTCLICKS. For more information about us, see Section 17.
2. How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process.
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; an
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type
2.3 We may process your account data (“account data”). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.4 We may process information contained in any
2.5 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
2.6 We may process information contained in or relating to any communication that you send to us] (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.7 We may process any of your personal data identified in this policy
2.8 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.9 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.4 We may disclose your
data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the
3.5 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or
4. International transfers of your personal data
4.2 We and our other group companies have offices and facilities in Scotland and England. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
4.3 The hosting facilities for our website are situated in London and the United States. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
4.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. Retaining and deleting personal data
5.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.3 We will retain your personal data as follows:
(a) personal data category or categories will be retained while you are an active VASTCLICKS customer.
5.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
(a) the period of retention of personal data category will be determined by the length of time necessary for the purpose(s) for which we originally collected it or until you withdraw your consent for us to do so.
5.5 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may notify you of changes to this policy by email or through the message notification system in the VASTCLICKS dashboard.
7. Your rights
7.1 In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes
the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise or
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation,
unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are
or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us.
8. Third party websites
8.1 Our website includes hyperlinks to, and details of, third party websites.
8.2 We have no control over,
and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1 Our website and services are targeted at persons over the age of 18.
9.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
10.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
11.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
12.1 We use both session cookies and persistent cookies for the following purposes:
and to protect our website and services generally.
13. Cookies used by our service providers
13.2 We use Google Analytics to
The relevant cookies are: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage/
13.3 We use HotJar to analyze the use of our website. HotJar gathers information about website use by means of cookies. The information gathered relating to our website is used to improve our website by enabling our web team to find and fix errors and improve the functionality of the website. To do this HotJar may record mouse clicks, mouse movements, page scrolling and any text keyed into web site forms. The information collected is stored and is also used for aggregated and statistical reporting.
The relevant cookies are explained at:
14. Managing cookies
14.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however
obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer).
(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
14.2 Blocking all cookies will have a negative impact upon the usability of many websites.
14.3 If you block cookies, you will not be able to use all the features on our website.
15. Our details
15.1 This website is owned and operated by Adidit Limited trading as VASTCLICKS.
15.2 We are registered in Scotland under registration number SC543669, and our registered office is at 6.3 Turnberry House, 175 West George Street, Glasgow, G2 2LB.
15.3 Our principal place of business is at 6.3 Turnberry House, 175 West George Street, Glasgow, G2 2LB.
15.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
16. Data protection officer
16.1 Our data protection officer’s contact details are: Stuart McLeod
Please e-mail any questions or comments you have about this policy to [email protected] Everyone realizes why a new common language would be desirable: one could refuse to pay expensive translators. To achieve this, it would be necessary to have uniform grammar, pronunciation and more common words.
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