Last updated: 7 October 2026
Virtual Headquarters Limited (VHQ) values your privacy and respects the rights you have in relation to your personal data. This Privacy Notice (Notice) lets you know how we use your personal data and provides details of your rights under data protection law.
It is important that you read this Notice together with any other privacy notice(s) we may provide so that you are fully aware of how and why we are using your personal data. This notice supplements all other privacy notices provided by us and is not intended to override them.
| Key term | Definition |
|---|---|
| personal data | any information about an individual who is identified or identifiable |
| special categories of personal data | any information about you which relates to your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, your health as well as genetic data and biometric data for the purpose of uniquely identifying you. |
| criminal offence data | any personal data relating to criminal convictions and offences or related security measures. |
| Description | Personal data |
|---|---|
| Communication Data | The channel and method by which we communicate with you, the contents of communications with you, including emails, correspondence and, where applicable, telephone call recordings. |
| Contact Data | Correspondence addresses, personal and professional email addresses, details of the company you work for, contact information in social media profiles, personal and professional telephone numbers and business cards |
| Financial Data | bank account details, billing information, transaction and payment card information |
| Identity Data | Full name, title, date of birth, gender, residential address, email address, copies of government-issued identification documents (including passports and driving licences), a live “selfie” image of your face which is used to create a biometric template for the purpose of facial matching with your identity document, SmartSearch verification results. |
| Marketing Data | your preferences in receiving marketing from us |
| Transaction Data | details about payments to and from you and other details of services we have provided to you and details of services you provide to us where you are a supplier or provider of goods and services |
| Technical Data | internet protocol (IP) address, browser type and version, time zone setting, location, browser plug-in types and versions and operating system and platform |
| Usage Data | information about how you use our website and services |
| Call Recording Data | Audio recordings of telephone calls, together with any information discussed during the call and associated metadata, such as the date, time and telephone number. |
| Collection method | Description |
|---|---|
| Direct interactions | Most of the personal data we collect and use comes directly from you in person, by telephone or via email |
| Automated technologies or interactions | As you interact with our website, we automatically collect Technical data. We collect this personal data by using cookies, server logs and other similar technologies. You can see a copy of our cookie notice by clicking on the cookie banner on our website. |
| Third parties | We receive personal data about you from the third parties listed below: a) SmartSearch – identity verification information and electronic identity verification results as part of the customer due diligence process. b) Professional advisers and authorised representatives – including accountants, solicitors or other representatives authorised to act on your behalf, where they provide information in connection with our services. c) Regulatory, law enforcement and government bodies – where personal data is provided to us to enable us to comply with our legal and regulatory obligations. |
| Via our IT systems | We automatically collect certain technical information when you use our website or online services. This may include your IP address, browser type and version, device information, operating system, usage data, cookies and similar technologies. |
| Publicly available sources | We may receive personal data from publicly available sources where this is necessary to carry out customer due diligence, comply with our legal and regulatory obligations or undertake ongoing monitoring. These sources include Companies House, sanctions lists, Politically Exposed Person (PEP) registers, insolvency registers, publicly available adverse media and publicly accessible social media information used as part of customer due diligence and ongoing monitoring. |
| Individual | Purpose for processing | Data used | Legal basis relied on |
|---|---|---|---|
| Prospective Customers | To respond to enquiries received by telephone, email, our website or other communication channels and provide information about our services. | Identity Data, Contact Data, Communication Data, Call Recording Data | Legitimate interests – to respond to enquiries, provide information about our services and promote our business. |
| Prospective Customers | To assess whether our services are suitable for your requirements and provide quotations or proposals where requested. | Identity Data, Contact Data, Communication Data | Legitimate interests – to assess enquiries and provide information about our services before a contract is entered into. |
| Prospective Customers | To create customer records and progress the onboarding process before entering into a contract. | Identity Data, Contact Data, Communication Data | Performance of a contract – to take steps at your request before entering into a contract (Article 6(1)(b) UK GDPR). |
| Prospective Customers and Customers | To verify the identity of directors, Persons with Significant Control (PSCs) and Authorised Account Persons (AAPs) during customer onboarding using our identity verification provider. | Identity Data, Contact Data, Communication Data | Legal obligation – to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Explicit consent to process biometric data for the purpose of identification verification through facial matching during the customer onboarding process |
| Prospective Customers and Customers | To carry out Customer Due Diligence (CDD), verify customer identity, assess customer risk and determine whether a business relationship can be established or continued. | Identity Data, Contact Data, Communication Data | Legal obligation – to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. |
| Prospective Customers and Customers | To carry out sanctions screening before establishing, and where appropriate during, the business relationship. | Identity Data, Contact Data | Legal obligation – to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. |
| Prospective Customers and Customers | To identify whether customers or associated individuals are Politically Exposed Persons (PEPs), their family members or known close associates and determine the appropriate level of customer due diligence. | Identity Data, Contact Data | Legal obligation – to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. |
| Prospective Customers and Customers | To undertake adverse media screening as part of our risk-based customer due diligence procedures. | Identity Data, Contact Data | Legitimate interests – to identify and assess potential financial crime, reputational and customer risk as part of VHQ’s risk-based customer due diligence procedures. |
| Prospective Customers and Customers | To communicate with customers throughout the onboarding process, request additional information where required and notify customers of the outcome of their application. | Identity Data, Contact Data, Communication Data | Performance of a contract – to take steps at your request before entering into a contract and administer the onboarding process. |
| Customers and individuals who have opted in to marketing | To send marketing communications about our services, updates and promotional offers where permitted by law. | Marketing Data, Identity Data, Contact Data, Communication Data, Technical Data, Usage Data | Legitimate interests to send marketing communications about our services to existing customers in relation to similar services, where they have not opted out of receiving such communications. Consent where the requirements for relying on our legitimate interests are not met. Individuals may withdraw their consent or unsubscribe from marketing communications at any time. |
| Customers | To provide services in accordance with the customer’s instructions and the agreed contract. | Identity Data, Contact Data, Communication Data, Transaction Data | Performance of a contract – to provide the services requested by the customer and administer the contractual relationship. |
| Customers | To administer customer accounts, maintain customer records, manage authorised contacts, process account changes and communicate important information relating to the customer’s account and services. | Identity Data, Contact Data, Communication Data, Transaction Data | Performance of a contract – to administer the customer relationship and provide our services. |
| Customers | To verify the identity of customers and authorised contacts before making changes to customer accounts or services, including verifying their authority to request account changes. | Identity Data, Contact Data, Communication Data | Performance of a contract – to protect customer accounts, prevent unauthorised access and administer our services securely. |
| Customers | To process subscriptions, issue invoices, collect payments, administer refunds where applicable and maintain accounting records relating to the services provided. | Identity Data, Contact Data, Communication Data, Transaction Data | Performance of a contract – to administer our services and process payments. Legal obligation – to comply with applicable tax and accounting legislation. |
| Customers | To provide customer support, respond to service requests, investigate account queries and resolve issues relating to the services provided. | Identity Data, Contact Data, Communication Data, Transaction Data | Performance of a contract – to provide customer support and administer our services. |
| Customers | To manage customer cancellations, terminate services, calculate final charges and fulfil our legal and regulatory obligations following the end of the business relationship. | Identity Data, Contact Data, Communication Data, Transaction Data | Performance of a contract – to administer the termination of the contractual relationship. Legal obligation – to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. |
| Customers | To disclose identity verification information to authorised London Building Partners where necessary to enable them to comply with their legal or regulatory obligations relating to occupiers using their premises. | Identity Data, Contact Data, Communication Data | Our legitimate interest in providing London Building Partners with the records they need to comply with the London Local Authorities Act 2007, so that VHQ can offer the virtual office service in these locations to customers. |
| Suppliers | To onboard suppliers, maintain supplier records, administer supplier accounts, manage contractual relationships, communicate with suppliers and process payments for goods and services provided to VHQ. | Identity Data, Contact Data, Financial Data, Transaction Data, Communication Data | Performance of a contract – to administer supplier relationships and fulfil our contractual obligations. |
| Customers | To carry out ongoing monitoring of customer relationships, including reviewing customer information, ownership structures and account activity where required throughout the business relationship. | Identity Data, Contact Data, Communication Data, Transaction Data | Legal obligation – to comply with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. |
| Customers, Prospective Customers and Suppliers | To prevent, detect and investigate fraud, financial crime, unauthorised use of our services and other unlawful activity. | Identity Data, Contact Data, Communication Data, Transaction Data, Technical Data, Usage Data | For our recognised legitimate interest to detect, investigate or prevent crime |
| Customers | To investigate, manage and respond to complaints, disputes and service issues. | Identity Data, Contact Data, Communication Data, Transaction Data | Legitimate interests – to investigate complaints, improve our services and protect our business. |
| Customers | To disclose personal data where required by law or in response to requests from regulators, law enforcement agencies, courts or other competent authorities. | Identity Data, Contact Data, Communication Data, Transaction Data | Legal obligation – to comply with applicable legal and regulatory obligations. |
| All individuals covered by this Privacy Notice | To establish, exercise or defend legal claims and protect the legal rights and interests of VHQ. | Identity Data, Contact Data, Communication Data, Financial Data, Transaction Data, Technical Data, Usage Data | Legitimate interests – to establish, exercise or defend legal claims and protect our business and legal rights. |
| All individuals covered by this Privacy Notice | To carry out internal audits, quality assurance reviews, compliance monitoring and respond to regulatory inspections or investigations. | Identity Data, Contact Data, Communication Data, Transaction Data | Legal obligation – to comply with applicable legal and regulatory obligations. Legitimate interests – to monitor compliance, improve our services and maintain effective business governance. |
| All individuals covered by this Privacy Notice | To administer, maintain and protect our IT systems, website, networks and business infrastructure, including monitoring system performance, troubleshooting, maintaining security and preventing unauthorised access. | Identity Data, Contact Data, Technical Data, Usage Data | Legitimate interests – to maintain the security, availability and integrity of our systems and services. |
| Website Users | To operate our website, analyse website usage, improve functionality and manage cookies and similar technologies. | Technical Data, Usage Data | Legitimate interests – to operate and improve our website. Consent – where required for non-essential cookies and similar technologies. |
| All individuals covered by this Privacy Notice | To maintain business records, produce management information, undertake business planning and ensure the effective administration of our business. | Identity Data, Contact Data, Communication Data, Transaction Data | Legitimate interests – to manage and develop our business effectively. |
| All individuals covered by this Privacy Notice | To comply with applicable legal, regulatory, accounting and tax obligations, maintain statutory records and demonstrate compliance with our legal responsibilities. | Identity Data, Contact Data, Communication Data, Financial Data, Transaction Data | Legal obligation – to comply with applicable legal and regulatory obligations, including company, tax and data protection legislation. |
You may receive marketing communications from us if you are an existing customer and we are permitted by law to send you marketing communications about similar services, provided you have not opted out of receiving them.
Where consent is required, you will only receive electronic marketing communications where you have actively opted in, for example by selecting the relevant marketing tick box on our website.
We do not currently send marketing communications to prospective customers unless they have specifically opted in to receive them.
Where you opt out of receiving marketing communications, this will not prevent us from contacting you where necessary in connection with your account, the services we provide to you, or our legal or regulatory obligations.
| Third party | Personal data shared | Reason for sharing personal data | Is your personal data sent outside of the UK/EEA? |
|---|---|---|---|
| Microsoft 365 (Microsoft Ireland Operations Limited) | Identity Data, Contact Data, Communication Data, Technical Data, Usage Data and customer records. | To provide email, document management, cloud storage and business IT infrastructure. | Yes – Microsoft may process personal data outside the UK. Appropriate safeguards, including the UK International Data Transfer Addendum and/or Standard Contractual Clauses (SCCs), are in place where required. |
| Google Workspace (legacy systems only, where applicable) | Identity Data, Contact Data, Communication Data and historical customer records. | To retain historical business records held in legacy systems. | Yes – Google may process personal data outside the UK/EEA. Appropriate safeguards, including the UK International Data Transfer Addendum and/or Standard Contractual Clauses (SCCs), are in place where required. |
| BZB IT Solutions | Identity Data, Contact Data, Communication Data, Technical Data and customer records where access is required. | To provide IT support, system administration and maintenance. | No. |
| Pipedrive | Identity Data, Contact Data, Communication Data, Marketing Data and customer account information. | To manage customer relationships, sales opportunities and customer accounts. | No. |
| Chargebee | Identity Data, Contact Data, Financial Data, Transaction Data and Communication Data. | To manage subscriptions, billing and payment processing. | Yes – Chargebee may process personal data outside the UK/EEA. Appropriate safeguards, including the UK International Data Transfer Addendum and/or Standard Contractual Clauses (SCCs), are in place where required. |
| Xero | Identity Data, Contact Data and Transaction Data. | To maintain accounting records and prepare financial reports. | Yes – Xero may process personal data outside the UK/EEA. Appropriate safeguards, including the UK International Data Transfer Addendum and/or Standard Contractual Clauses (SCCs), are in place where required. |
| Third party | Personal data shared | Reason for sharing personal data | Is your personal data sent outside of the UK/EEA? |
|---|---|---|---|
| HM Revenue & Customs (HMRC) | Identity Data, Contact Data, Transaction Data and accounting records where required. | To comply with our legal and tax obligations. | No. |
| Information Commissioner’s Office (ICO) | Identity Data, Contact Data, Communication Data and other information relevant to the matter. | To comply with our obligations under data protection legislation. | No. |
| Other regulators and competent authorities | Identity Data, Contact Data, Communication Data, Transaction Data and other information required by law. | To comply with legal and regulatory obligations. | No. |
| Third party | Personal data shared | Reason for sharing personal data | Is your personal data sent outside of the UK/EEA? |
|---|---|---|---|
| SmartSearch | Identity Data, Contact Data, copies of identification documents, identity verification results and customer due diligence information. | To carry out electronic identity verification, sanctions screening, PEP screening, adverse media screening and customer due diligence. | No. |
| Third party | Personal data shared | Reason for sharing personal data | Is your personal data sent outside of the UK/EEA? |
|---|---|---|---|
| Banking providers and payment service providers used by VHQ | Identity Data, Contact Data, Financial Data and Transaction Data. | To process payments, administer banking facilities and manage financial transactions relating to our services. | No, unless the provider processes personal data outside the UK/EEA. Where this occurs, appropriate safeguards will be implemented. |
| Data type | Retention period |
|---|---|
| Customers | Customer records and Customer Due Diligence (CDD) records are retained for 6 years after the business relationship ends in accordance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. Where a longer retention period is required by law, we will retain the information for as long as necessary to comply with our legal obligations. |
| Prospective Customers | Where an application is not completed and no identification documents have been submitted, personal data will be retained for 3 months from the date the application is abandoned or closed. Where an application is declined following Customer Due Diligence, personal data will be retained for 6 years to comply with our legal and regulatory obligations. |
| Suppliers | Supplier records will be retained for 6 years after the end of the business relationship, unless a longer retention period is required to comply with legal, regulatory or accounting obligations. |
| Website visitors | Please see our Cookie Notice for information about the retention periods applicable to cookies and similar technologies used on our website. |
t: +44 (0)330 223 2605
e: [email protected]
a: Virtual Headquarters Limited, Leigh Court Business Centre, Abbots Leigh, Bristol, BS8 3RA, United Kingdom.
End of notice