Last updated: March 2021

Rubix VT are committed to protecting the personal information that you provide to us, in adherence to Data Protection Legislation (defined below) and best business practice.

This Privacy Notice describes Rubix VT’s practices in relation to the use of its websites and the related products, applications and services offered by Rubix VT. This Privacy Notice sets out how we use and protect any personal data that you provide to us, including personal data provided through its Website.

Rubix VT provides software and hardware products, and services to its customers and as a result may collect and process personal data about individuals (“Services”).

Rubix VT maintains the same practices with data that is collected off-line and this notice may be relied upon with respect to those methods of data collection and use.

Rubix VT may modify or update its Privacy Notice at any time without prior notice. You can check the “Last updated” date above to see when the notice was last changed.

How to contact us

If you have any questions regarding your personal data and how we may use it, including any queries relating to this Privacy Notice, please email hello@rubixvt.com, or write to the ‘Privacy Notice’ at Rubix VT, Europa House, 46-50 Southwick Square, Southwick, West Sussex, BN42 4FJ.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Terminology used

Rubix VT’s data protection and privacy measures are governed by the

1. the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then
2. any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation”).

For the purpose of Data Protection Legislation:

1. where personal data is provided directly to Rubix VT through use of its website, email, or other means where Rubix VT is determining the way in which that personal data is processed, then Rubix VT will be a data controller of such information; and
2. where Rubix VT is provided personal data in its capacity of providing Services to its customers, then Rubix VT will only process that personal data in accordance with the instructions of its customers and Rubix VT will therefore act as a data processor in respect of such personal data; Rubix VT’s customer will be the data controller of that personal data for that purpose.

Where Rubix VT acts as a data processor on behalf of its customers, Rubix VT will process that personal data on the instructions of the customer, who would have collected that personal data in accordance with that customer’s own privacy policy. The data subject should therefore check the customer’s own privacy policy, to ensure they understand how their personal data may be processed.

Information we collect

Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Rubix VT will only collect basic personal data about you, such as your name, email address, business type, work address, job title (“identity data”) and any product/solution interests that you have shared (“preferences data”) and information relating to your use of our Websites (“usage data”). Unless otherwise agreed with you, this information will not include any special categories of personal information (often known as “sensitive personal data”).

When visiting our Website, information is captured using cookies. To find out more about our use of website cookies, please visit our Cookie Policy.

We use different methods to collect personal data from and about you including through:

• Direct interactions. You may give us your contact information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when we provide you with Services; or
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as:
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services including third party debt agencies; and
  • Identity and Contact Data from publicly available sources such as Companies House

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 (or our customer whom we act for) and you fail to provide that data when requested, we may not be able to perform the contract we have or trying to enter. In this case, we may have to cancel the Services but we will notify you (or where appropriate, our customer) if this is the case at the time.

How we use information that we collect

Rubix VT will only use your personal data when the law allows it to, i.e. if we have a legal basis for doing so, as outlined in this Privacy Notice or as notified to you at the time in which we collect your personal data, and for the purposes for which it was collected for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and will explain the legal basis which allows it to do this. Please note that Rubix VT may process your personal data without your knowledge or consent, where this is required or permitted by law.

Rubix VT will use your personal data to carry out its contractual obligations and, in addition, to keep you up-to-date with its products and services that you have expressed an interest in.

Where Rubix VT acts as the data controller for customer contact information, it has set out below in the table a description of all the ways it plans to use your personal data, and which of the legal bases Rubix VT relies on to do so. Rubix VT has also identified what its legitimate interests are, where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground that it is relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you or the company that you are connected to as a new customer and verify your identity (where required)	Identity / contact data	Performance of a contract Consent (for use of special categories of data, if applicable)
To perform credit checks	Identity / contact data	Legitimate interests
To process and deliver the Services including: (a) Manage accounts, payments, fees and charges (b) Contacting you and corresponding about the Services	Identity / contact data	Performance of a contract Necessary for RubixVT’s legitimate interests (to recover debts due to Rubix VT)
To respond to queries and enquiries	Identity / contact data	Legitimate interests
To undertake marketing to you	Identity / contact / preferences data	Legitimate interests

Where Rubix VT acts as a data processor of personal data on behalf of its customers, in accordance with our customers’ instructions or in order to comply with a legal or regulatory obligation.

How your personal data may be shared

Where Rubix VT acts as the data controller for customer contact information, or where permitted by Rubix VT’s data controller customers, personal data processed by us may be shared as follows:

• • With permitted third party contractors of Rubix VT for the purposes of performing its Services;

 

• Where Rubix VT is under a duty to disclose your personal data to comply with any legal obligation, or to enforce or apply our terms and conditions and other agreements;
• To protect the rights, property, or safety of Rubix VT, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws; and

Rubix VT requires 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.

Rubix VT will not share your information for marketing purposes with third party companies.

You can choose to unsubscribe from Rubix VT marketing communications at any time using the unsubscribe option on any electronic communication sent from us. You may continue to receive further communications where a contractual or legitimate interest exists.

How long we keep your information for

Where Rubix VT acts as a data controller, it will not keep your personal information longer than is necessary for the purpose in which it was provided, unless required by law, or for other legitimate reasons that need it to be retained for longer (for example, if necessary for any legal proceedings).

Where Rubix VT acts as a data processor on behalf of its customers, we will only hold on to personal data for the period notified to Rubix VT by the data controller customer, or for the period required for the purposes of satisfying any legal, accounting, regulatory or reporting requirements

Your rights

Under Data Protection Legislation, you have the following rights in certain circumstances:

• The right to be informed – this is information on Rubix VT’s collection and use of your personal data.
• The right of access – you have the right to be provided with copies of the personal data of you that Rubix VT is processing as well as confirmation of the processing Rubix VT is doing. You can do this by sending a “subject access request” to the contact details noted above for Rubix VT’s consideration.
• The right to rectification – if you think the personal data that Rubix VT holds on you is wrong, you can inform us and we will fix it.
• The right to erasure (also known as the right to be forgotten) – if you want us to permanently delete the personal data we hold about you then you can ask us to do so.
• The right to restrict processing – if you do not like how we are using your personal data then you can let us know and we will stop processing it in that way.
• The right to data portability – if you want us to pass on your personal data to someone else then please let us know. This transfer should not affect the integrity or otherwise damage your personal data.
• The right to withdraw your consent – you can withdraw your consent for Rubix VT to process your personal data (if we have relied on your consent to process your personal data) at any time by contacting us. If we have relied only on your consent as the basis to process your personal data then we will stop processing your personal data at the point you withdraw your consent. Please note that if we can also rely on other bases to process your personal data aside from consent then we may do so even if you have withdrawn your consent.
• Rights in relation to automated decision making and profiling – if Rubix VT uses either automated decision making or profiling then you have a right to know. Also, Rubix VT needs your consent if either of these are used to make a decision that affects you. As with all consent, you can withdraw it at any time.

Where you exercise your right to erasure or where information is deleted in accordance with Rubix VT’s retention policy, please note that after the deletion of your personal data, it cannot be recovered. So if you require a copy of this personal data, please request this during the period Rubix VT retains the data.

Where you exercise your right to request access to the information Rubix VT processes about you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, Rubix VT may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Alternatively, Rubix VT may refuse to comply with your request in these circumstances. Rubix VT will try to respond to all legitimate access requests within one month. Occasionally, it may take longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Children

Rubix VT website is not intended for children and we will not knowingly collect any personal data from persons under the age of 18 and will immediately delete any such data subsequently so determined.

How to raise a concern about the use of your personal information

If you have concerns about how Rubix VT has handled your personal data, including in relation to any of the rights contained herein, please contact us outlining the concerns that you have. You may also make a complaint to the ICO (the UK supervisory authority). You can find further information about the ICO and their complaints procedure at: https://ico.org.uk/concerns/.

IP Addresses

Rubix VT Websites may collect your Internet Protocol (IP) address. This information is collected for internal security and system administration purposes. This information may also be used to trace the computer used in cases of misuse or unlawful actions in connection with visits to or use of our website.

External websites

Rubix VT’s website may, from time to time, contain links to other websites. If you follow a link to another website, please note that the website will have its own privacy policy and that we do not accept any responsibility or liability for such policies, or how such websites collect and use your data. Please check the associated privacy policy before you submit any personal data to these websites.

Rubix VT
Sussex Innovation Centre, Brighton BN1 9SB

020 3740 4923
hello@rubixvt.com