Last updated: (26 October 2020)

This Privacy Policy outlines how The Virtual Hub Ltd (“we”, “us”, or “our”), the controller of your personal data, collect, use, maintain and disclose information collected from customers and prospective customers with regards to our “services”. Services refers to the features that we offer, including our Virtual Assistants, customer support, and website. This privacy policy applies to the site www.thevirtualhub.com, any subdomains, and all services offered by The Virtual Hub.

The Virtual Hub limited, a company limited by guarantee. Registered office: 801-2 Tung Hip Commercial Building, 244-248 Des Voeux Road Central, Hong Kong, Hong Kong

Data Protection Officer: Tom McNamara

Email: [email protected]

For all data protection matters, please contact Tom McNamara at the details above.

Our EU Representative is Barbara Turley who is located in France.  

 

What Information We Collect 

While using our Services, we may collect the following information: 

• Communication data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. 
• Customer data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details.
• User data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services.
• Technical data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. 
• Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences.

How We Collect Personal Information

We may collect personal information from you in a variety of ways, including when you: 

• Engage in direct interactions, such as providing us with your identity, contact and financial data by filling our forms or corresponding with us by post, phone, email or otherwise. 
• Apply for or pay for our products or services
• Subscribe to our service or publications
• Request marketing materials to be sent to you
• Enter a competition, promotion or survey
• Provide feedback
• Interact with our website, which may automatically collect Technical Data about your equipment, browsing actions and patterns through our use of cookies (link to cookies policy)

We may receive data from third parties such as analytics providers, such as Google, advertising networks such as Facebooks, search information providers, such as Google, and providers of technical, payment and delivery services, such as data brokers or aggregators.

 

Our Lawful Basis for Collecting Personal Information

We will collect personal information from customers only with the following lawful bases:

 

Consent	Where you have provided explicit permission for us to use your information for a specified purpose
Contract	Where you have entered into an agreement with us, such as downloading our app or purchasing a product, to allow us to fulfil our contractual obligations with you
Legitimate interest	Where we have a legitimate interest in doing so, for example, protect our legal interests or improve our Service
Legal obligation	Where we are legally obliged to do so, such as for tax reporting

 

Web browser cookies 

When someone visits one of our websites, we collect standard internet log information and details about visitor behaviour patterns. We do this to find out information such as the number of visitors to the various parts of the site and their browsing preferences. 

Most web browsers allow some control of the placement of most cookies through the browser settings. To find out more about our cookies please see our Cookies Policy (link to Cookies Policy).

 

How we use collected information 

The Virtual Hub may collect and use customers personal information for the following purposes: 

• To communicate with you
• To keep records
• The establishment, pursuance or defence of legal claims
• To supply and keep records of the services you have purchased
• To operate our website 
• To ensure that relevant content is provided to you
• To ensure the security of our website 
• To maintain backups of our website 
• To enable publication and administration of our website and other online services and business. 
• To analyse your use of our website and other online services
• To administer and protect our business and website
• To deliver relevant website content and advertisements to you 
• To understand the effectiveness of our advertising.
• To enable you to partake in our promotions such as competitions, prize draws and free giveaways
• To deliver relevant website content and advertisements to you 
• To measure or understand the effectiveness of this advertising

If you decide to opt-in to our mailing list, then you may receive correspondence via email, which may include updates, company news, information about related products or services, etc. If you would like to unsubscribe from receiving future messages at any time and for any reason, you may do so by following the unsubscribe instructions included at the bottom of each email, or you can contact us through our website.

 

Your Rights

As per applicable data protection laws, you may have the right to access the personal information about you that The Virtual Hub processes.

You can request from us information about:

• The personal data we hold about you
• The purposes of the processing of your personal data
• Details regarding whom your personal data has/will be disclosed to or the criteria for the disclosure
• How long we retain your personal data
• In cases where your data was not collected directly from you, information regarding the source of the data.

You may also request the following:

• That we delete your personal data
• That we update any inaccurate or incomplete data about you
• That we make your personal data portable

We only hold accurate, complete and up-to-date personal information about you; therefore, we strongly encourage you to contact us for correcting any incomplete or inaccurate data.

You may request any actions regarding your rights by contacting us at The Virtual Hub Data Protection Officer at the contact details above. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or if you have made a number of requests. In this case, we will notify you.

To ensure that your data is protected, if you request to exercise your rights, we will first require you to verify your identity before we can respond to your request.

We regularly review all data that is supplied and obtained to enable us to delete data which is not necessary or no longer needed. We do this in line with our Data Retention Policy detailed below. 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Irish Data Protection Commissioner (DPC), the Irish supervisory authority for data protection issues (www.dataprotection.ie). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

 

How we protect your information  

We adopt best in class technical and organisational security practices, which are subject to regular review, and security measures such as staff training and awareness, to protect against unauthorised access, disclosure, alteration, or destruction of your personal information.

We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

 

Sharing your personal information 

We may engage third-party service providers to help us operate our business or to administer activities on our behalf. We may share your information with these third parties for those limited purposes as per this policy. We only engage with trusted third parties, each of which are held to high standards with regard data protection obligations and security. 

We may share your personal data with:

• Professional advisers including lawyers, bankers, auditors and insurers
• Government bodies that require us to report processing activities.

We do not and will not sell or deal in personal or customer information. We will never disclose your personal details to a third party except the necessary information required by providers of products or services you have purchased or to protect the rights, property or safety of thevirtualhub.com, its customers or third parties or if required by law.

 

How Long and Where We Retain Your Data 

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  For further details on our data retention periods, please contact us. 

Where you have consented to us to use your details for direct marketing, we will keep this data until you notify us or otherwise withdraw your consent.

 

International Transfers

Our business is built on commonly available software tools and solutions, in some cases, there may be an international transfer of data to our providers located around the world, such as Microsoft. We take steps to ensure that the necessary level of protection for these transfers is applied in compliance with applicable laws and regulations.

 

Third Party Extensions and Links

Our Site includes links to other websites whose privacy policies we do not control. When you access another website, the use of any information you provide is governed by the privacy policy of the operator of the site you are visiting.

 

Changes to this privacy policy 

The Virtual Hub has the discretion to update this privacy policy at any time. When we do, we will notify customers of any significant changes which may affect your rights.