Last updated: 24th April 2024
At Virtual Headquarters Limited, we are proud that we are fully compliant with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).
This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information. We regret that if there are one or more points below with which you are not happy, your only recourse is to leave our website immediately. We undertake to preserve the confidentiality of all information you provide to us and hope that you reciprocate.
Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regard to the processing and control of your personal data. You can see further information about your rights, and our obligations, at www.ico.org.uk.
Except as set out below, we do not share, sell, or disclose to a third party, any information collected through our website.
1. Our core beliefs regarding user privacy and data protection
2. Relevant legislation
Along with our business and internal computer systems, this website is designed to comply with the following national and international legislation with regard to data protection and user privacy:
This site’s compliance with the above legislation, all of which are stringent in nature, means that this site is likely compliant with the data protection and user privacy legislation set out by many other countries and territories as well.
3. Personal information that this website collects and why we collect it
The law requires us to determine under which basis we process different categories of your personal information and to notify you of the basis for each category. If the basis on which we process your personal information is no longer relevant, then we shall immediately stop processing your data.
3.1 Information we process because we have a contractual obligation to you
When you create an account on our website, buy a product or service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us. To carry out our obligations under that contract we must process the information you give us. Some of this information may be personal information.
We will use it in order to:
• Sell products to you
• Provide you with our services
• Provide you with suggestions and advice on products, services and how to obtain the most from using our website
• Verify your identity under The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
We process this information on the basis there is a contract between us, or that you have requested we use the information before we enter into a legal contract. Additionally, we may aggregate this information in a general way and use it to provide class information, for example, to monitor our performance with respect to a service we provide. If we use it for this purpose, you as an individual will not be personally identifiable. We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.
3.2 Information we process with your consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you with more information about our business, including our products and services, you provide your consent to us to process information that may be personal information.
In order to facilitate the delivery of our services to you, we have a number of agreements in place with recognised office space providers. We only share personal data with the office space provider that operates at the chosen location that you have selected as your office address, this is an integral part of us being able to deliver our services to you. To minimise the risk to your privacy, we only share the minimum amount of personal data necessary to both deliver the services to you and to meet the local regulatory responsibilities at each chosen office space location.
3.3 Information we process because we have a legal obligation
We require personal information to adhere to The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, this includes photo identification and proof of address. It is our legal obligation to collect this and cannot commence our service to you without this information. We will keep this data for as long as you remain a customer, and then for six years following the cancellation of your account to adhere to current legislation. To find out more about our Money Laundering processes, please follow this link. http://www.virtual-headquarters.com/money-laundering-regulations-virtual-offices/
In compliance with prevailing laws, please note that certain regulations take precedence over the right to request the erasure of personal data. Once you submit your personal data, you are waiving your entitlement to request its deletion. However, you retain the option to request removal from our advertising communications.
When submitting your personal documents to Virtual Headquarters via Jotform, please be aware that you are doing so at your own risk. While Jotform is fully compliant with relevant regulations, Virtual Headquarters cannot be held responsible for any data breaches that may occur on their behalf.
Upon submission, all client data is stored on Business GDrive and, where applicable, PipeDrive CRM. Both platforms are fully compliant with relevant regulations. However, it’s important to note that Virtual Headquarters cannot be held responsible for any breaches of the organisation’s systems. Rest assured, we select our software with the utmost consideration for compliance and security.
3.4 Information we share within our group
Virtual Headquarters Limited operates under Chadwick Holdings Limited ownership. Within our group, data may be shared as appropriate. Additionally, we work with various partners to deliver services across UK buildings. To facilitate these services, we may need to share your personal data with the respective partner involved.
Under UK AML laws, there may be instances where we are required to share your AML documentation, submitted during our onboarding process, with the partner. Such sharing will only occur when necessary to comply with the law.
It’s important to note that all virtual office services in London are subject to the London Authority Act. To comply, we will share all documentation provided, including any additional due diligence completed, with the centre itself to be held on-site. By ordering a virtual office in London and submitting your documentation, you are permitting us to share where applicable.
Please be aware that each of our partners has its own privacy policy. Virtual Headquarters cannot be held responsible for any breaches in their data security measures.
If you prefer not to have your data shared, kindly reach out to us before submitting the documents. Please note that opting out may result in the cancellation of your order, and the nonrefundable setup fee will be retained.
4.0 This website collects and uses personal data for the following reasons
By using this website, users consent to the collection and use of their personal data for the aforementioned purposes. Users have the right to access, modify, or delete their personal data as permitted by applicable laws and regulations. For inquiries or requests regarding personal data, users can contact us through the contact information provided on the website.
4.1 Site visitation tracking
Similar to many other websites, this site utilises tools including, but not limited to, Google Analytics and other cookies to track user interactions. The purpose of collecting this data is to assess the usage of our site, gain insights into how visitors discover and navigate our web pages, and analyze their journey throughout the website.
While Google Analytics captures information such as geographical location, device type, internet browser, and operating system, none of this data personally identifies individuals to us. Additionally, Google Analytics records the IP address of your computer, which theoretically could be used for personal identification. However, Google does not provide us access to this information. We consider Google to be a third-party data processor (refer to section 7.0 below).
Please note that this website respects user privacy and takes necessary measures to safeguard personal data in accordance with applicable laws and regulations.
4.2 Contact forms and email links
Should you choose to contact us using the contact form on our Contact Us page or an email link, none of the data that you supply will be stored by this website or passed to / processed by any of the third-party data processors defined in section 6.0. Instead, the data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (sometimes known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography before being sent across the internet. The email content is then decrypted by our local computers and devices.
Virtual Headquarters utilises Gravity Forms for the submission of contact forms on our website. These forms are integrated with Pipedrive CRM. By submitting your details via the contact form, you consent to the sharing of your data with these systems.
When you provide us with information about another person, you must confirm that they have appointed you to act for them and consent for us to process their personal data. They will have the opportunity at any time to amend their marketing preferences.
4.3 Sending a message to our support team
When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need. We record your request and our reply in order to increase the efficiency of our business. We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a quality service.
4.4 Contacting us by telephone
By contacting us via phone and providing your contact details, you agree to allow us to contact you using the provided means of communication. If you wish to opt out of this communication method, please notify us in writing.
Please note that all calls are recorded for training and monitoring purposes.
4.5 Complaining
When we receive a complaint, we record all the information you have given to us. We use that information to resolve your complaint.
5.0 Website hosting
This website is hosted by Parrot Creative Ltd which acts as our third-party data processor for our website data, and has UK/EU data processing agreements in place with all data centre and hosting partners.
6.0 Our third-party data processors
We use several third parties to process personal data on our behalf. These third parties have been carefully chosen. Some of these third parties are based in the USA and are EU-U.S Privacy Shield compliant.
Please note, that your data will not be automatically shared with all the above third parties and will only be processed where necessary.
7.0 Access to your personal information
You have the right to review or update personally identifiable information held about you at any time. To obtain a copy of your information, please send a request to [email protected]. We aim to process data requests within 21 working days, in compliance with GDPR regulations.
Please note that to receive this information, you must complete our data access request form. Requests made without submission of all the information required in the form will be declined, as it is necessary for our record-keeping purposes.
Data provided will be limited to the following:
What we don’t provide:
7.1 How long we keep your personal information for
How long personal information will be retained depends on the type of information it is and what it is being used for. Where we are processing your information for marketing purposes, we will continue to do so until such a time as you inform us that you wish to be removed from our marketing database. If you ask us not to send you marketing emails, we will stop storing your emails for marketing purposes (although we will keep a record of your preference not to be emailed).
7.2 Removal of your information
In certain circumstances you can ask for the data we hold about you to be deleted, however as stipulated in point 3.3 of this policy, we are required to retain data relating to our Anti-Money Laundering responsibilities for 6 years post-termination of our contract with you.
7.3 How you can complain
If you are not happy with our privacy policy or if have any complaints, then you should tell us by email.
If you are in any way dissatisfied with how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns/.
8.0 Registration with the information commissioner’s office (ICO)
Virtual Headquarters Limited is officially registered with the Information Commissioner’s Office (ICO) under registration reference: ZA179926.
9.0 Internal breach
Any breach of our privacy policy internally is a direct violation of our commitment to safeguarding user data and maintaining trust. It undermines the fundamental principles of integrity and responsibility that govern our operations. Addressing such breaches swiftly and transparently is imperative to uphold our standards and preserve the confidence of our users.
10.0 Changes to our privacy policy
This Privacy Policy may change from time to time in line with legislation or industry developments. We will not explicitly inform our clients or website users of these changes. Instead, we recommend that you check this page occasionally for any policy changes. Specific policy changes and updates are mentioned in the changelog below.
