Privacy & Cookie Notice

Introduction

Who we are

We are Torpedo Group Limited trading as Viewteam, referred to as “we”, “us”, “our” and “Viewteam” in this notice. See ‘Our details’ section below for further information about us.

Scope of this notice

This notice describes our processing of personal data we obtain about:

visitors to our viewteam.com website
users of our Viewteam platform at app.viewteam.com
staff and representatives of our business customers

For the purposes of UK and EU data protection law, we are the ‘controller’ of this personal data (meaning that we determine why and how it is processed).

This notice does not explain our processing of personal data as a processor on behalf of our business customers who use Viewteam products. This processing is instead described in and governed by contracts between us and our business customers.

This notice does not describe our processing of personal data relating to people who apply for jobs with us. Our processing for recruitment purposes is set out in a separate notice for job applicants available on our ’Applicant Data Privacy Notice’ webpage. Neither does this notice describe our processing of personal data relating to our employees. Our processing for employment-related purposes is set out in a separate notice that we make available to our employees.

Types of personal data we process

Business contact data: Data relating to our business customers’ staff and representatives collected in connection with providing Viewteam to our customers, such as names and business email addresses, postal addresses, telephone numbers and job titles. This data might be provided by the business, by the individuals themselves or by their colleagues.
Account data: Data collected for the purpose of setting up customer user accounts to enable our business customers’ staff to access the Viewteam platform, such as names, usernames, email addresses and access permissions. This might be provided by the business, by the individuals themselves or by their colleagues.
Correspondence data: Information contained in or relating to any correspondence we receive, including any personal data contained in the content, address and contact details and any metadata associated with the correspondence such as the date and time of sending. We obtain this data when people contact us by email, phone, post or via social media.
Enquiry data: Information we obtain when website visitors complete and submit forms on our website. This information is provided to us by people who complete and submit forms on our website, and our website generates communication metadata associated with the forms.
Website usage data: Data about website visitors’ use of our website and platform users’ use of our Viewteam platform, such as IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths. This data is collected automatically using our platform event log and cookies – see section on ‘Our use of cookies’ below.
Marketing data: Information collected in connection with any marketing subscription or opt-out request, such as email addresses and marketing preferences.
Marketing campaign data: Information collected in connection with our marketing email campaigns, such as openings and click-throughs by recipients. This data is collected automatically using cookies, tracking pixels and similar technologies – see section on ‘Our use of cookies’ below.

Why we use personal data

Core processing purposes

The purposes for which we use personal data in the normal course of our business, the types of personal data we use for those purposes and our legal bases for doing so are set out in the table below.

Purposes of processing	Types of personal data	Legal basis
Providing Viewteam to our customers and communicating with customers in connection with providing those services	Business contact data	Our legitimate interests in providing our products and services to customers
Recognising and authenticating our customers’ Viewteam users	Account data Website usage data	Our legitimate interests in enabling our customers to access and use Viewteam and keeping our website, network and systems secure
Monitoring our customers’ use of Viewteam for billing purposes	Account data Website usage data	Our legitimate interests in billing customers for use of our products and services based upon their usage
Billing customers for use of Viewteam	Business contact data	Our legitimate interests in charging customers for using our products and services
Communicating with people, for example in response to an enquiry or complaint	Enquiry data Correspondence data	Our legitimate interests in responding to and communicating with customers, potential customers and users of our products and services
Providing our customers with (non-marketing) service information relevant to our customers generally, such as any maintenance work or problems affecting access to or use of Viewteam	Business contact data Account data Website usage data	Our legitimate interests in administering our business, services and website and communicating important service information to customers and users
Sending marketing communications (see more on this in the ‘Using personal data for marketing purposes’ section below	Marketing data Business contact data	Our legitimate interests in promoting our business, products and services to drive sales and sustain and grow our business
Customer relationship management, including dealing with complaints, keeping records of our interactions with customers and keeping in contact with customers	Business contact data Enquiry data Correspondence data Website usage data	Our legitimate interests in providing a good quality service to our customers, dealing effectively with complaints and maintaining relationships with our customers
Analysing use of our website and Viewteam platform registration pages, e.g. finding out how people navigate to and between various parts of the site and the Viewteam platform registration pages, so that we can assess how successful our website and online advertising is and how they could be improved or developed	Website usage data	Consent of our website visitors via a cookie preference tool on our website
Keeping our Viewteam platform secure and functional	Website usage data	Our legitimate interests in protecting our Viewteam platform and ensuring it works effectively
Monitoring the success of our email marketing campaigns	Marketing campaign data	Our legitimate interests in understanding the best methods to promote our business, products and services to grow our business

For the purposes of marketing

We send occasional emails and physical mailings containing information about our business, products and services to the following categories of people:

staff and representatives of our business customers or target business customers
people who have subscribed to receive our newsletter or other marketing communications

If you receive such communications from us and do not wish to, you can tell us by using the unsubscribe link in any email we send to you or emailing [email protected].

Other processing purposes

In addition to our core processing purposes set out above, we may also process personal data if and to the extent necessary for the following purposes:

Purpose	Legal basis
Establishing, exercising or defending legal claims	Our legitimate interests in defending legal claims brought against us, enforcing claims against others and protecting and asserting our legal rights and the legal rights of you and others
Obtaining or maintaining insurance coverage, managing risks or obtaining professional advice	Our legitimate interests in protecting our business against risks
Compliance with a legal obligation such as a statutory or regulatory obligation or an order of a court, government body or regulator	Compliance with a legal obligation
In order to protect your vital interests or the vital interests of another natural person	Protection of vital interests

Recipients of personal data

We may share the personal data described in this notice with the following categories of recipients, where and to the extent necessary for the purposes described in this notice:

Group companies: our subsidiary companies, our ultimate holding company and all its subsidiaries.
Insurers and professional advisers: such as lawyers, accountants and business and marketing consultants, but only if and to the extent necessary for them to carry out the work we engage them to assist us with, for example in relation to a legal claim made against us or obtaining insurance coverage.
Organisations or individuals engaged by us in the course of providing our services: such as individual consultants or their personal service companies who provide software/website programming/development/marketing services or assist with providing support and maintenance services to our customers.
Prospective buyer: if we propose to sell or do sell any of our business or assets, we may make personal data available to a prospective buyer for the purposes of pre-sale due diligence or to a buyer as information assets transferred as part of the sale – for example a prospective buyer may request details of any outstanding legal claim against us, or a buyer may acquire ownership of our business contacts/customer databases.
Service providers: We use a number of service providers in connection with our website, services, communications and IT infrastructure, which involves those service providers processing some of the personal data described in this notice to the extent necessary to provide the relevant services. See our Service Provider list for details of the service providers we currently use.

We have contracts with all our service providers to ensure that they treat the personal data they receive in compliance with applicable data protection laws, including that they only process the personal data described in this notice to the extent necessary to provide the services.

There may also be circumstances in which we need to share personal data with other organisations or individuals, such as where disclosure is necessary for the purposes set out in the ‘Other processing purposes’ section above, including complying with legal obligations to disclose information.

In all cases, we will only share personal data with such recipients where and to the extent reasonably necessary for the relevant processing purpose and in accordance with applicable data protection law.

International transfers of personal data

The personal data we process is hosted and stored on servers situated in the United Kingdom (UK).

We transfer some personal data to the service providers described in the ‘Recipients of personal data’ section above that are based in countries outside the UK. See our Service Provider list for details of these transfers and the safeguards in place to protect personal data once it has been transferred.

In addition to the known transfers described above, it may become necessary to transfer personal data described in this notice to organisations based outside the UK in connection with the purposes described in the ‘Other processing purposes’ section above, such as to comply with a legal obligation or to defend or bring a legal claim. If this happens, we would ensure that such a transfer complies with the conditions for transfers stipulated by applicable data protection law.

Security of personal data

We will take appropriate technical and organisational precautions to secure the personal data we process and prevent accidental or unlawful destruction, loss or alteration and unauthorised disclosure of, or access to, that personal data, as described in our Data Security Schedule.

If you have an account to access Viewteam via our website, you must ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping your password confidential. We will not ask you for your password (except when you log in to our website).

Unfortunately the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

We will notify affected individuals and any applicable regulator of any personal data breach where we are legally required to do so.

Retention and deletion of personal data

We will only retain the personal data described in this notice for as long as necessary to fulfil the processing purposes described in this notice.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements.

We will apply the following general retention periods and/or retention criteria to the personal data described in this notice:

Business contact data: We keep this in our accounting and CRM databases for up to 7 years after the relevant customer contract has terminated.
Account data: We delete this on or shortly after the termination of the relevant customer contract in accordance with the data deletion provisions set out in that contract.
Correspondence data: We store emails for 2 years after the date of the correspondence, but if the email relates to a customer contract, we store them for up to 7 years after termination of the customer contract to which the email relates.
Enquiry data: Submitted web contact forms are stored for up to 2 years. We receive the data in the form of emails, which we store for up to 2 years.
Website usage data: The statistical reports provided to us by Google are retained by us for up to 14 months. However, these contain only aggregated data that do not enable us to identify individual users.
Marketing data: We will continue to use this data until we receive an opt-out request, after which time we will retain the email address and marketing preference information to ensure that we do not send marketing to the unsubscribed email address.
Marketing campaign data: We will retain this data for up to 2 years.

These retention periods are subject to any longer retention periods that may be necessary for compliance with a legal obligation or in order to defend or bring legal claims.

Our use of cookies

What is a cookie?

A cookie is a small text file containing an identifier (a string of letters and numbers) that is saved on your computer or mobile device when you visit our website or use the Viewteam platform. The identifier is then sent back to our server each time your browser requests a page from our server.

Cookies are either “persistent” cookies or “session” cookies: a persistent cookie will be stored by your web browser and remain valid until its set expiry date, unless deleted by you before the expiry date; a session cookie, on the other hand, will expire when you close your web browser.

Cookies do not typically contain any information that personally identifies a website user, but we might theoretically be able to identify individuals by linking any personal data we already have with information stored in and obtained from cookies.

Our use of cookies

We keep the use of cookies to the minimum we can. Most are essential cookies that are necessary to enable our Viewteam platform and Help Centre to function, and to help with security and fraud prevention, and the cookies on our website help us market our business effectively. We use Help Scout to host content for our Help Centre knowledge hub and to manage support enquiries.

Cookies on our website, in the Viewteam platform and on our Help Centre

See our Cookie List for details of the cookies used on our website at viewteam.com, within Viewteam on app.viewteam.com and if you use our Help Centre.

Cookies on third party sites linked from the Viewteam platform

Some actions taken by users within our Viewteam platform will result in them being routed to third party websites, for example:

to Microsoft’s website when using Microsoft single sign on to login to the platform
to Help Scout’s website when using the help centre knowledge base

Those third party websites may place cookies on your server when you visit them. We have no control over such cookies or websites. Please refer to the cookie notice of the relevant third party for information about the cookies used on those websites.

Managing cookies

We provide a cookie preference tool which allows you to accept or reject various types of cookies when you visit our website. This will be presented to you the first time you visit our website and can be accessed at any time from our website.

If you use the cookie preference tool to reject any cookies you previously accepted, this will not delete those previously accepted cookies from your browser. You will need to clear the cookies from your browser if you wish to delete them. Information on how to do this can be found by visiting www.allaboutcookies.org/how-to-clear-cookies.

You can learn more about cookies by visiting www.allaboutcookies.org which includes useful information on cookies and how to block them using different types of browser.

Please note that if you block all cookies including those necessary to enable you to use and navigate the website and Viewteam platform, our website and the Viewteam platform may become inaccessible or not function properly.

Your rights

You have a number of different rights you might be able exercise against us in relation to personal data about you that we process. These are rights to:

access your personal data
obtain rectification or erasure of your personal data
restrict and/or object to processing of your personal data
have your personal data ‘ported’ to you or another organisation
complain to a supervisory authority about our processing of your personal data
withdraw consent to our processing of your personal data (where you have given consent)

The availability of these rights varies depending on the legal basis that we rely on for processing the relevant personal data. Below we have summarised these rights and explained how you can request to exercise them.

Access: 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 that the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

Rectification: You have the right to have any inaccurate personal data about you corrected and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. We may need to verify the accuracy of the new data you provide to us.

Erasure: You have the right to the erasure of your personal data without undue delay where the personal data are no longer necessary in relation to the purposes for which we collected or otherwise processed them, you successfully object to our processing, you object to our use of your personal data for direct marketing purposes, we have processed your personal data unlawfully, or an applicable law requires the relevant personal data to be erased. However, there are exclusions to the right to erasure, including where we have overriding legitimate grounds to continue processing the relevant personal data or are required to do so by applicable law or where we need it to establish, exercise or defend a legal claim.

Restriction: You have the right to restrict our processing of your personal data where you contest the accuracy of the personal data, our processing is unlawful, we no longer need the personal data for our purposes but you require it to establish, exercise or defend a legal claim, or you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it to establish, exercise or defend a legal claim, to protect the rights of another natural or legal person or for reasons of important public interest or with your consent.

Object: You have the right to object to our processing of your personal data where we rely on legitimate interests as the legal basis for the processing. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

Object to processing for direct marketing purposes: You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes).

Data portability: where our processing of your personal data is based on performance of a contract or consent and 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. This right does not apply to our processing because we only use consent as the legal basis for using analytic cookies on our website, which does not provide us with data that is attributable to individuals.

Complain to a supervisory authority: If you consider that our processing of your personal data 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.

Withdraw consent: where any of our processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

How to exercise these rights against us: You can exercise any of your rights in relation to your personal data that require any action by us by emailing your request to [email protected] in addition to any other methods specified in this policy. Please be aware that if your request relates to any processing that we carry out as a processor on behalf of your employer, we will inform you of this and advise you to make the request to your employer, because they will be the controller in relation to that processing who is responsible under data protection laws for responding to your request.

How to complain to a supervisory authority: To make a complaint to a supervisory authority, you may contact the supervisory authority of your choice using contact details made available by that supervisory authority. Relevant contact details for the UK supervisory authority, the ICO, can be found here: https://ico.org.uk/concerns/.

Our details

We are Torpedo Group Limited trading as Viewteam, a private limited company incorporated in England and Wales (registered company number 4889983), whose registered office is at The Long Barn, Worton Park, Cassington, Oxon, OX29 4SX, United Kingdom.

We are registered as a data controller with the UK Information Commissioner’s Office. Our data protection registration number is Z8616043.

For enquiries relating to this notice or our processing of personal data, please contact our Data Protection Lead at [email protected].

You can also contact us using the web contact form or any of the contact details published on the ‘Contact’ page of our website from time to time.

Changes to this notice

We may update this notice from time to time by publishing a new version on our website and, where any changes materially affect you, we will also make reasonable efforts to notify you.