We will treat your data in accordance with our privacy policy.

Purpose

This policy establishes an effective, accountable and transparent framework for ensuring compliance with the requirements of the GDPR (General Data Protection Regulation).

Scope

This policy applies to all Virtualtech Solutions (“Company”) employees responsible for the processing of personal data on behalf of Company’s services/entities.

Sharing information

We collect personal information that you voluntarily provide to us, such as your name, email address, phone number, and any other information that you choose to share with us, but we do not sell, rent, or disclose your personal information to third parties without your consent, except as necessary to provide requested services or as required by law. We respect your privacy choices, especially concerning the sharing of your personal information. Any information you provide through opt-in consent will not be shared with third parties for marketing or promotional purposes. We Safeguard your data, we are highly cautious about entrusting it to anyone beyond. We firmly believe in maintaining control over your personal information and ensuring it is confidential and secure at all times. Consequently, we are committed to exercising discretion and discretion when it comes to sharing any personal details with external entities.

Policy Statement

Company is committed to conducting its business in accordance with all applicable data protection laws and regulations and in line with the highest standards of ethical conduct.

This policy sets forth the expected behaviors of Company’s employees in relation to the collection, use, retention, transfer, disclosure and destruction of any personal data belonging to a Company contact (i.e. the data subject).

Personal data is any information (including opinions and intentions) that relates to an identified or identifiable natural person. Personal data is subject to certain legal safeguards and other regulations that impose restrictions on how organizations may process personal data. An organization that handles personal data and makes decisions about its use is known as a Data Controller. Company, as a Data Controller, is responsible for ensuring compliance with the data protection requirements outlined in this policy. Non-compliance may expose Company to complaints, regulatory action, fines and/or reputational damage.

Governance

Data Protection Officer

To demonstrate our commitment to data protection, and to enhance the effectiveness of our compliance efforts, Company has appointed a Data Protection Officer. The Data Protection Officer operates with independence and is supported by suitably skilled individuals granted all necessary authority. 

The Data Protection Officer reports to Company’s CEO. The Data Protection Officer’s duties include:

• Informing and advising Company and its employees who carry out processing pursuant to data protection regulations, national law or European Union-based data protection provisions;
• Ensuring the alignment of this policy with data protection regulations, national law or European Union based data protection provisions;
• Providing guidance with regards to carrying out Data Protection Impact Assessments (DPIAs);
• Acting as a point of contact for and cooperating with Data Protection Authorities (DPAs);
• Determining the need for notifications to one or more DPAs because of Company’s current or intended personal data processing activities;
• Making and keeping current notifications to one or more DPAs because of Company’s current or intended personal data processing activities;

The establishment and operation of a system providing prompt and appropriate responses to data subject requests;
Informing senior managers, officers, and directors of Company of any potential corporate, civil and criminal penalties that may be levied against Company and/or its employees for violation of applicable data protection.

Data Protection

To ensure that all data protection requirements are identified and addressed when designing processes and/or when reviewing or expanding existing systems or processes, each of them must go through an approval process before continuing. Each Company service/entity must ensure that a Data Protection Impact Assessment (DPIA) is conducted, in cooperation with the Data Protection Officer, for all new and/or revised systems or processes for which it has responsibility. The subsequent findings of the DPIA must then be submitted to the CEO for review and approval. Where applicable, the Information Technology (IT) department, as part of its IT system and application design review process, will cooperate with the Data Protection Officer to assess the impact of any new technology uses on the security of personal data.

Compliance Monitoring

To confirm that an adequate level of compliance that is being achieved by all Company services/entities in relation to this policy, the Data Protection Officer will carry out an annual data protection compliance audit for all such services/entities. Each audit will, as a minimum, assess:

Compliance with policy in relation to the protection of personal data, including: The assignment of, Raising, Training of, The effectiveness of data protection-related operational practices, including:

• Data subject
• Personal data
• Personal data incident
• Personal data complaints
• The level of understanding of data protection policies and privacy
• The currency of data protection policies and privacy
• The accuracy of personal data being
• The conformity of data processor

The adequacy of procedures for redressing poor compliance and personal data breaches. The Data Protection Officer, in cooperation with key business stakeholders from each Company service/entity, will devise a plan with a schedule for correcting any identified deficiencies within a defined and reasonable time frame. Any major deficiencies and good practice identified will be reported to, monitored and shared by the Company’s executive team.

Data Protection Principles

Company has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of personal data:

Principle 1: Lawfulness, Fairness and Transparency. Personal data shall be processed lawfully, fairly and in a transparent manner in relation to the data subject. This means that Company must tell the data subject what processing will occur (transparency), the processing must match the description given to the data subject (fairness), and it must be for one of the purposes specified in the applicable data protection regulation (lawfulness).

Principle 2: Purpose Limitation. Personal data shall be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. This means Company must specify exactly what the personal data collected will be used for and limit the processing of that personal data to only what is necessary to meet the specified purpose.

Principle 3: Data Minimization. Personal data shall be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed. This means Company must not store any personal data beyond what is strictly required.

Principle 4: Accuracy. Personal data shall be accurate and, kept up to date. This means Company must have processes in place for identifying and addressing out-of- date, incorrect and redundant personal data.

Principle 5: Storage Limitation. Personal data shall be kept in a form that permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. This means Company must, wherever possible, store personal data in a way that limits or prevents identification of the data subject.

Principle 6: Integrity & Confidentiality. Personal data shall be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing, and against accidental loss, destruction or damage. Company must use appropriate technical and organizational measures to ensure the integrity and confidentiality of personal data is maintained at all times.

Principle 7: Accountability. The Data Controller shall be responsible for, and be able to demonstrate compliance. This means Company must demonstrate that the six data protection principles (outlined above) are met for all personal data for which it is responsible.

Data Collection 

Data Sources

Personal data should be collected only from the data subject unless one of the following applies:

The nature of the business purpose necessitates collection of the personal data from other persons or
The collection must be carried out under emergency circumstances in order to protect the vital interests of the data subject or to prevent serious loss or injury to another
If personal data is collected from someone other than the data subject, the data subject must be informed of the collection unless one of the following applies:

The data subject has received the required information by other
The information must remain confidential owing to a professional secrecy
A national law expressly provides for the collection, processing or transfer of the personal
Where it has been determined that notification to a data subject is required, notification should occur promptly, but in no case later than:

One calendar month from the first collection or recording of the personal
At the time of first communication if used for communication with the data
At the time of disclosure if disclosed to another.

Data Subject Consent

Each Company service/entity will obtain personal data only by lawful and fair means and, where appropriate with the knowledge and consent of the individual concerned. Where a need exists to request and receive the consent of an individual prior to the collection, use or disclosure of their personal data, Company is committed to seeking such consent. The Data Protection Officer, in cooperation with other relevant business representatives, shall establish a system for obtaining and documenting data subject consent for the collection, processing, and/or transfer of their personal data.

Data Subject Notification

Each Company service/entity will, when required by applicable law, contract, or where it considers that it is reasonably appropriate to do so, provide data subjects with information as to the purpose of the processing of their personal data. When the data subject is asked to give consent to the processing of personal data and when any personal data is collected from the data subject, all appropriate disclosures will be made, in a manner that draws attention to them, unless one of the following apply:

The data subject already has the information;
A legal exemption applies to the requirements for disclosure and/or consent. The disclosures may be given orally, electronically or in writing. If given orally, the person making the disclosures should use a suitable script or form approved in advance by the Data Protection Officer. The associated receipt or form should be retained, along with a record of the facts, date, content, and method of disclosure.
External Privacy Notices

Each external website provided by Company will include an online ‘Privacy Notice’ and an online ‘Cookie Notice’ fulfilling the requirements of applicable law.

Data Use

Data Processing

Company uses the personal data of its contacts for the following broad purposes:

The general running and business administration of Company services/entities.
To provide services to Company’s
The ongoing administration and management of customer services.
The use of a contact’s information should always be considered from their perspective and whether the use will be within their expectations or if they are likely to object. For example, it would clearly be within a contact’s expectations that their details will be used by Company to respond to a contact request for information about the products and services it offers. However, however, it is certain that the Company, in any case would not provide their details to third parties for marketing purposes.

Each Company service/entity will process personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, Company will not process personal data unless at least one of the following requirements is met:

The data subject has given consent to the processing of their personal data for one or more specific
Processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
Processing is necessary for compliance with a legal obligation to which the Data Controller is obliged to.
Processing is necessary in order to protect the vital interests of the data subject or of another natural
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller.

Special Categories of Data

Company will only process special categories of data (also known as sensitive data) where the data subject expressly consents to such processing or where one of the following conditions apply:

The processing relates to personal data that has already been made public by the data
The processing is necessary for the establishment, exercise or defense of legal
The processing is specifically authorized or required by
The processing is necessary to protect the vital interests of the data subject or of another natural person where the data subject is physically or legally incapable of giving
Further conditions, including limitations, based upon national law related to the processing of genetic data, biometric data or data concerning
In any situation where special categories of data are to be processed, prior approval must be obtained from the Data Protection Officer, and the basis for the processing clearly recorded with the personal data in question. Where special categories of data are being processed, Company will adopt additional protection measures.

Data Quality

Each Company service/entity will adopt all necessary measures to ensure that the personal data it collects and processes is complete and accurate in the first instance, and is updated to reflect the current situation of the data subject. The measures adopted by Company to ensure data quality include:

Correcting personal data known to be incorrect, inaccurate, incomplete, ambiguous, misleading or outdated, even if the data subject does not request
Keeping personal data only for the period necessary to satisfy the permitted uses or applicable statutory retention
The removal of personal data if in violation of any of the data protection principles or if the personal data is no longer required.
Restriction, rather than deletion of personal data, insofar as: a law prohibits
erasure would impair legitimate interests of the data
The data subject disputes that their personal data is correct, and it cannot be clearly ascertained whether their information is correct or incorrect.
Profiling & Automated Decision Making

Company will only engage in profiling and automated decision-making where it is necessary to enter into, or to perform, a contract with the data subject or where it is authorized by law. Where a Company service/entity utilizes profiling and automated decision-making, this will be disclosed to the relevant data subjects. In such cases the data subject will be given the opportunity to:

Express their point of
Obtain an explanation for the automated
Review the logic used by the automated
Supplement the automated system with additional
Have a human carry out a review of the automated
Contest the automated Object to the automated decision-making being carried out.
Each Company service/entity must also ensure that all profiling and automated decision-making relating to a data subject is based on accurate data.

Digital Marketing

As a general rule, Company will not send promotional or direct marketing material to a Company contact through digital channels such as mobile phones, email and the Internet, without first obtaining their consent. Any Company service/entity wishing to carry out a digital marketing campaign without obtaining prior consent from the data subject must first have it approved by the Data Protection Officer. Where personal data processing is approved for digital marketing purposes, the data subject must be informed at the point of first contact that they have the right to object, at any stage, to having their data processed for such purposes. If the data subject puts forward an objection, digital marketing related processing of their personal data must cease immediately, and their details should be kept on a suppression list with a record of their opt-out decision, rather than being completely deleted. It should be noted that where digital marketing is carried out in a ‘business to business’ context, there is no legal requirement to obtain an indication of consent to carry out digital marketing to individuals provided that they are given the opportunity to opt-out.

Data Retention

To ensure fair processing, personal data will not be retained by Company for longer than necessary in relation to the purposes for which it was originally collected, or for which it was further processed.

Data Protection

Each Company service/entity will adopt physical, technical, and organizational measures to ensure the security of personal data. This includes the prevention of loss or damage, unauthorized alteration, access or processing, and other risks to which it may be exposed by virtue of human action or the physical or natural environment. A summary of personal data-related security measures is provided below:

Prevent unauthorized persons from gaining access to data processing systems in which personal data is
Prevent persons entitled to use a data processing system from accessing personal data beyond their needs and
Ensure that personal data in the course of electronic transmission during transport cannot be read, copied, modified or removed without
Ensure that access logs are in place to establish whether, and by whom, the personal data was entered into, modified on or removed from a data processing
Ensure that in the case where processing is carried out by a Data Processor, the data can be processed only in accordance with the instructions of the Data
Ensure that personal data is protected against undesired destruction or
Ensure that personal data collected for different purposes can and is processed
Ensure that personal data is not kept longer than.
Law Enforcement Requests & Disclosures

In certain circumstances, it is permitted that personal data be shared without the knowledge or consent of a data subject. This is the case where the disclosure of the personal data is necessary for any of the following purposes:

The prevention or detection of
The apprehension or prosecution of
The assessment or collection of a tax or
By the order of a court or by any rule of
If a Company service/entity processes personal data for one of these purposes, then it may apply an exception to the processing rules outlined in this policy but only to the extent that not doing so would be likely to prejudice the case in question. If any Company service/entity receives a request from a court or any regulatory or law enforcement authority for information relating to a Company contact, you must immediately notify the Data Protection Officer who will provide comprehensive guidance and assistance.

Data Protection Training

All Company employees that have access to personal data will have their responsibilities under this policy outlined to them as part of their staff induction training. In addition, each Company service/entity will provide regular Data Protection training and procedural guidance for their staff.

Complaints Handling

Data subjects with a complaint about the processing of their personal data, should put forward the matter in writing to the Data Protection Officer. An investigation of the complaint will be carried out to the extent that is appropriate based on the merits of the specific case. The Data Protection Officer will inform the data subject of the progress and the outcome of the complaint within a reasonable period. If the issue cannot be resolved through consultation between the data subject and the Data Protection Officer then the data subject may, at their option, seek redress through mediation, binding arbitration, litigation, or via complaint to the Data Protection Authority within the applicable jurisdiction.

Breach Reporting

Any individual who suspects that a personal data breach has occurred as a result of the theft or exposure of personal data must immediately notify the Data Protection Officer providing a description of what occurred. The Data Protection Officer will investigate all reported incidents to confirm whether or not a personal data breach has occurred. If a personal data breach is confirmed, the Data Protection Officer will follow the relevant authorized procedure based on the criticality and quantity of the personal data involved. For severe personal data breaches, the Company’s Executive Team will initiate and chair an emergency response team to coordinate and manage the personal data breach response.

Records Management

Staff must maintain all records relevant to administering this policy and procedure in electronic form in a recognized Company recordkeeping system. All records relevant to administering this policy and procedure will be maintained for a period of five years.

Terms and Definitions

Data Controller: the entity that determines the purposes, conditions and means of the processing of personal data. Data Processor: the entity that processes data on behalf of the Data Controller.

Data Protection Authority: national authorities tasked with the protection of data and privacy as well as monitoring and enforcement of the data protection regulations within the Union.

Data Protection Officer (DPO): an expert on data privacy who works independently to ensure that an entity is adhering to the policies and procedures set forth in the GDPR.

Data subject: a natural person whose personal data is processed by a controller or processor.

Personal Data: any information related to a natural person or ‘data subject’ that can be used to directly or indirectly identify the person.

Privacy Impact Assessment: a tool used to identify and reduce the privacy risks of entities by analyzing the personal data that are processed and the policies in place to protect the data.

Processing: any operation performed on personal data, whether or not by automated means, including collection, use, recording, etc. Profiling: any automated processing of personal data intended to evaluate, analyze, or predict data subject behavior.