Privacy Policy

Virtual-Landline Privacy policy
Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we are acting as a data controller and / or a data processor with
respect to the personal data of our website visitors and service users; in other words, where we
determine the purposes and means of the processing of that personal data.
1.3 We may cookies on our website. Insofar as those cookies are not strictly necessary for the
provision of our website and services, we may ask you to consent to our use of cookies when you
first visit our website.
1.4 Our website may incorporate privacy controls which may affect how we will process your
personal data. By using the privacy controls, you can specify whether you would like to receive direct
marketing communications and limit the publication of your information. You can request access to
the privacy controls via info@virtual-landline.com
1.5 In this policy, “we”, “us” and “our” refer to Virtual-Landline. For more information about us, see Section
13.
1.6 In this policy, “customers”, “you” and “your” refer to Businesses entities who use our services,
or Businesses entities who are potential customers for our business telephone and other services
Credit
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific
categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (“usage data“). The usage
data may include your IP address, geographical location, browser type and version, operating
system, referral source, length of visit, page views and website navigation paths, as well as
information about the timing, frequency and pattern of your service use. The source of the usage
data is our analytics tracking systems. This usage data may be processed for the purposes of
analysing the use of the website and services. The legal basis for this processing is consent and / or
our legitimate interests, namely monitoring and improving our website and services

3.3 We may process your account data (“account data“). The account data may include your name,
company name, contact details including email address. The source of the account data is you, your
employer or a 3rd party referrer. The account data may be processed for the purposes of operating
our website, providing our services, ensuring the security of our website and services, maintaining
back-ups of our databases and communicating with you. The legal basis for this processing is consent
and / or our legitimate interests, namely the proper administration of our website and business and
/ or the performance of a contract between you and us and/or taking steps, at your request, to enter
into such a contract or to provide more information on our services.
3.4 We may process your information included in your personal profile on our website (“profile
data“). The profile data may include data may include your name, your name, address, telephone
number, email address, profile pictures, gender, date of birth, relationship status, interests and
hobbies, educational details, employment details, your company name and contact details and notes
on any contact you have had with the Company. The profile data may be processed for the purposes
of enabling and monitoring your use of our website and services. The legal basis for this processing is
our legitimate interests, namely the proper administration of our website and business and/or the
performance of services and/or a contract between you and us and/or taking steps, maybe at your
request, to enter into such a contract or to supply you with more information on our services.
3.5 We may process your personal data that are provided in the course of the use of our services
(“service data“). The service data may include your name, your company name and contact details
and notes on any contact you have had with the Company. The source of the service data is you or
your employer or third-party suppliers of goods and services as a result of legitimate interest to
provide us information as part of a package you have purchased or express interest in through
affirmative action. The service data may be processed for the purposes of operating our website,
providing our services, ensuring the security of our website and services, maintaining back-ups of
our databases and communicating with you. The legal basis for this processing is our legitimate
interests, namely the proper administration of our website and business and / or the performance of
a contract between you and us and/or taking steps, at your request, to provide information for you
to decide to enter into such a contract
3.6 We may process information that you post for publication on our website or through our
services (“publication data“). The publication data may be processed for the purposes of enabling
such publication and administering our website and services. The legal basis for this processing is
consent and / or our legitimate interests, namely the proper administration of our website and
business and / or the performance of a contract between you and us and/or taking steps, at your
request, to provide information for you to decide to enter into such a contract
3.7 We may process information contained in any enquiry you submit or any request for
information sent by a third party with your explicit permission on your behalf to us regarding goods
and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering,
marketing and selling relevant goods and/or services to you. The legal basis for this processing is
consent and / or our legitimate interests to offer you our services
3.8 We may process information relating to our customer relationships, including customer contact
information (“customer relationship data“). The customer relationship data may include your name,
names of employees, any related job titles or roles, business contact details, and information
contained in communications between us and you. The source of the customer relationship data is

you approaching us or a 3rd party referrer. The customer relationship data may be processed for the
purposes of managing our relationships with customers, communicating with customers, keeping
records of those communications and promoting our products and services to customers. The legal
basis for this processing is consent and / or our legitimate interests, namely the proper management
of our customer relationships
3.9 We may process information relating to transactions, including purchases of goods and
services, that you enter into with us and/or through our website (“transaction data“). The
transaction data may include your contact details, your card details and the transaction details. The
transaction data may be processed for the purpose of supplying the purchased goods and services
and keeping proper records of those transactions. The legal basis for this processing is the
performance of a contract between you and us and/or taking steps, at your request, to enter into
such a contract and our legitimate interests, namely the proper administration of our website and
business
3.10 We may process information that you provide to us for the purpose of subscribing to our email
notifications and/or newsletters (“notification data“). The notification data may be processed for the
purposes of sending you the relevant notifications and/or newsletters. The legal basis for this
processing is consent and / or our legitimate interests and / or the performance of a contract
between you and us and/or taking steps, at your request, to enter into such a contract
3.11 We may process information contained in or relating to any communication that you send to
us (“correspondence data“). The correspondence data may include the communication content and
metadata associated with the communication. Our website will generate the metadata associated
with communications made using the website contact forms. The correspondence data may be
processed for the purposes of communicating with you and record-keeping. The legal basis for this
processing is our legitimate interests, namely the proper administration of our website and business
and communications with users
3.12 We may process any of your personal data identified in this policy where necessary for the
establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure. The legal basis for this processing is our legitimate
interests, namely the protection and assertion of our legal rights, your legal rights and the legal
rights of others.
3.13 We may process any of your personal data identified in this policy where necessary for the
purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional
advice. The legal basis for this processing is our legitimate interests, namely the proper protection of
our business against risks.
3.14 In addition to the specific purposes for which we may process your personal data set out in this
Section 3, we may also process any of your personal data where such processing is necessary for
compliance with a legal obligation to which we are subject, or in order to protect your vital interests
or the vital interests of another natural person.
3.15 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
Providing your personal data to others

4.1 We may disclose your personal data to any member of our group of companies (this means our
subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary
for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as
reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing
risks, obtaining professional advice, or the establishment, exercise or defence of legal claims,
whether in court proceedings or in an administrative or out-of-court procedure.
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4.4 Financial transactions relating to our website and services are handled by our payment services
providers, at this time, WorldPay. We will share transaction data with our payment services
providers only to the extent necessary for the purposes of processing your payments, refunding such
payments and dealing with complaints and queries relating to such payments and refunds. You can
find information about the payment services providers’ privacy policies and practices at
www.worldpay.com
4.5 We may disclose your enquiry data to one or more of those selected third party suppliers of
goods and services identified on our website for the purpose of enabling them to contact you so that
they can offer, market and sell to you relevant goods and/or services. Each such third party will act
as a data controller in relation to the enquiry data that we supply to it; and upon contacting you,
each such third party will supply to you a copy of its own privacy policy, which will govern that third
party’s use of your personal data.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose
your personal data where such disclosure is necessary for compliance with a legal obligation to
which we are subject, or in order to protect your vital interests or the vital interests of another
natural person. We may also disclose your personal data where such disclosure is necessary for the
establishment, exercise or defence of legal claims, whether in court proceedings or in an
administrative or out-of-court procedure.
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Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help
ensure that we comply with our legal obligations in relation to the retention and deletion of
personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is
necessary for that purpose or those purposes.
6.3 We will retain your personal data as follows:
(a) Personal data will be retained for a minimum period of 3 months following 25/05/2018, and for
a maximum period of 24 months following 25/05/2018.
6.4 Intentionally left blank

6.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data
where such retention is necessary for compliance with a legal obligation to which we are subject, or
in order to protect your vital interests or the vital interests of another natural person.
Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this
policy.
7.3 We may notify you of significant changes to this policy by email
Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law.
Some of the rights are complex, and not all of the details have been included in our summaries.
Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a
full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 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 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. You can access your
personal data on request by visiting http://clients.BABNholdings.co.uk/CallShieldlogin/index.php
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into
account the purposes of the processing, to have any incomplete personal data about you completed.

8.5 In some circumstances you have the right to the erasure of your personal data without undue
delay. Those circumstances include: the personal data are no longer necessary in relation to the
purposes for which they were collected or otherwise processed; you withdraw consent to consent-
based processing; you object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have been unlawfully
processed. However, there are exclusions of the right to erasure. The general exclusions include
where processing is necessary: for exercising the right of freedom of expression and information; for
compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data.
Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but
you oppose erasure; we no longer need the personal data for the purposes of our processing, but
you require personal data for the establishment, exercise or defence of legal claims; and 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: with your consent; for the establishment, exercise or defence of legal claims;
for the protection of the rights of another natural or legal person; or for reasons of important public
interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your
particular situation, but only to the extent that the legal basis for the processing is that the
processing is necessary for: the performance of a task carried out in the public interest or in the
exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by
us or by a third party. If you make such an objection, we will cease to process the personal
information unless we can demonstrate compelling legitimate grounds for the processing which
override your interests, rights and freedoms, or the processing is for the establishment, exercise or
defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing
purposes (including profiling for direct marketing purposes). If you make such an objection, we will
cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical
research purposes or statistical purposes on grounds relating to your particular situation, unless the
processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in
order to take steps at your request prior to entering into a contract,
and such processing 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.

8.11 If you consider that our processing of your personal information 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.
8.12 To the extent that the legal basis for our processing of your personal information is consent,
you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of
processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us in
addition to the other methods specified in this Section 8.
8.14 In line with this Policy and with you expressed consent, your information may be shared with
our service partners who include (but are not limited to)
(a) Enable Media Limited and their subsidiaries including Web.com, Scoot
(b) Clever Accounts Limited
(c) Elevate Online Limited
(d) Tide Platform Limited
About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web
server to a web browser and is stored by the browser. The identifier is then sent back to the server
each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be
stored by a web browser and will remain valid until its set expiry date, unless deleted by the user
before the expiry date; a session cookie, on the other hand, will expire at the end of the user
session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal
information that we store about you may be linked to the information stored in and obtained from
cookies.
Cookies that we use
10.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate
our website
(b) status – we use cookies to help us to determine if you are logged into our website
(c) personalisation – we use cookies to store information about your preferences and to
personalise the website for you

(d) security – we use cookies as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login credentials, and to protect our website and
services generally
(e) advertising – we use cookies to help us to display advertisements that will be relevant to you
(f) analysis – we use cookies to help us to analyse the use and performance of our website and
services
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies
more generally

Cookies used by our service providers
11.1 Our service providers use cookies and those cookies may be stored on your computer when
you visit our website.
11.2 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at:
https://www.google.com/policies/privacy/.
11.3 We may publish Google AdSense interest-based advertisements on our website. These are
tailored by Google to reflect your interests. To determine your interests, Google will track your
behaviour on our website and on other websites across the web using cookies. You can view, delete
or add interest categories associated with your browser by visiting: https://adssettings.google.com.
You can also opt out of the AdSense partner network cookie using those settings or using the
Network Advertising Initiative’s multi-cookie opt-out mechanism at:
http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies,
and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that
an opt-out is maintained in respect of a particular browser, you may wish to consider using the
Google browser plug-ins available at: https://support.google.com/ads/answer/7395996.
Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for
doing so vary from browser to browser, and from version to version. You can however obtain up-to-
date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-
cookies (Internet Explorer);

(e) https://support.apple.com/kb/PH21411 (Safari); and
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
12.3 If you block cookies, you may not be able to use all the features on our website.
Our details
13.1 This website is owned and operated by Virtual-Landline Limited.
13.2 We are registered in England and Wales under registration number 4936853, and our
registered office is at 20 Coxon Street, Spondon, Derby, DE21 7JG
13.3 Our principal place of business is at 78 York Street, London, W1H 1DP
13.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
Data protection officer
14.1 Our data protection officer is currently Richard Taylor. His contact details are
info@virtual-landline.com and on the phone number published on our website from
time to time.