privacy policy

Viewture Limited (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy
Policy explains how your personal information is collected, used, and disclosed by Viewture
Limited. This Privacy Policy applies to our website, and its associated subdomains
(collectively, our “Service”) alongside our application, Viewture Limited.
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Controller for personal data
A “controller” is a person or organisation who alone or jointly determines the purposes for
which and the way any personal data is or is likely to be processed. Unless we notify you
otherwise Viewture Limited is the controller of your personal data for the purpose outlined
below. This privacy notice applies to the processing of personal data by us in connection
with any:
 Customers: For the provision of services by us to our customers who register to use
our services.
 Suppliers: For the provision of products and services to us by suppliers or service
providers.
 Visitors: As a visitor on our website.
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Types of personal data
Personal data or personal information means any information about an individual from which
that person can be identified. It does not include data where the identity has been removed.
This is known as anonymised data. Anonymised data falls outside the scope of data
protection laws. Viewture Limited may collect, use, store and transfer different kinds of
personal data about you which we have grouped together:
 Identity Data: includes first name, last name, username or similar identifier and title.
 Contact Data: includes billing address, delivery address, email address and
telephone numbers.
 Financial Data: includes bank account and payment card details.
 Transaction Data: includes details about payments to and from you and other details
for the provision of Services you have purchased from us.
 Technical Data: includes internet protocol (IP) address, your login data, browser type
and version, time zone setting and location, browser plug-in types and versions,
operating system and platform and other technology on the devices you use to
access our website.
 Profile Data: includes your username and password, searches made by you, your
ratings and comments, preferences, feedback and survey responses.
 Usage Data: includes information about how you use our website and services. Marketing and Communications Data: includes your preferences in receiving
marketing from us and our third parties and your communication preferences.
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How we collect your personal data
Directly from you: You give us your personal data in your direct interactions with us. Such
personal data includes Identity Data, Contact Data, Financial Data, Profile Data, Usage
Data, Technical Data, Marketing and Communications Data (i) by filling in forms on our
website (ii) by leaving ratings and comments (iii) by corresponding with us by email or post
(iv) by calling us over the telephone.
This includes personal data you provide when you:
 register to use our services.
 subscribe to our service or publications.
 request marketing to be sent to you.
 give us feedback or contact us.
 participate in our marketing or other promotional events.
 contact us if you have any concerns.
In addition, as an end customer you may voluntarily provide us with information that you
have made available on social media websites. If you provide us with any such information
we may collect publicly available information from the social media websites, you have
indicated. You can control how much of your information on social media websites is make
public by visiting these websites and changing your privacy settings.
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From use of our website
 Viewtures Limited gathers information and statistics collectively about visitors to the
Company's website. Analysis of this information demonstrates the most frequently
used sections of the website and assists us in continually improving the online
service. You give us your personal data, which includes Profile Data, Usage Data,
Technical Data and/or Marketing and Communications Data when you use our
website or which we have agreed with you to use or when you review any
publications or marketing material we send you. Please see our cookies notice for
more information.
Indirectly: Third-party sources: We receive Identity Data, Contact Data, Financial Data,
about you from third parties when:
 we provide our Services or other parties send us your personal data to enable the
provision of those services.
 you provide your personal data to a third party for the purpose of sharing it with us.
 we receive information from a third party that provides automated fraud detection
services to us.
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Providing personal data
Where we need to collect personal data by law or under the terms of a contract we have with
you and you do not provide that information when requested we may not be able to perform
the contract we have or are trying to enter into with you for example to provide you with our
services. In this case we may have to cancel our service but we will notify you if this is the
case at the time.

How we use your personal data
Viewtures Limited will only use your personal data when the law allows us to. We will use
your personal data in the following circumstances:
 Performance of a contract: Where we need to perform the contract we are about to
enter into or have entered into with you. For example when you sign up to our
services.
 Legal obligation: Where we need to comply with a legal obligation. For example, for
accounting or legal purposes.
 Legitimate interests: Where it is necessary for our legitimate interests or those of a
third party and your interests and fundamental rights do not override those interests.
 Consent: We do not generally rely on consent as a legal basis for processing your
personal data. Where we do rely on consent you have the right to withdraw consent
at any time. Please contact us at info@viewture.com to withdraw consent. Please
also see Marketing communications.
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Purposes for which we will use your personal data
We have set out below in a table format a description of all the ways we plan to use your
personal data and which of the legal bases we rely on to do so. We have also identified what
our legitimate interests are where appropriate.Note that we may process your personal data
for more than one lawful ground depending on the specific purpose for which we are using
your data. Please contact us if you need details about the specific legal ground we are
relying on to process your personal data where more than one ground has been set out in
the table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a member for the provision of our Services.
(a) Identity
(b) Contact
Performance of a contract with you.
To respond to any enquires.
(a) Identity
(b) Contact
(a) Performance of a contract with you
(b) Necessary for our legitimate interests.
To process and deliver our Services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us.
(a) Identity
(b) Contact
(c) Financial
(d) Transaction(e) Marketing and
Comms
(a) Performance of a contract with you
(b) Necessary for our legitimate interests i.e., to recover debts due to us.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey.
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and
Comms
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests i.e., to keep our records updated and to study how
customers use our products/ services.
To administer and protect our business and this website including troubleshooting, data
analysis, testing, system maintenance, support, reporting and hosting of data.
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests for running our business, provision of
administration and IT services, network security, to prevent fraud and in the context of a
business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand
the effectiveness of the advertising we serve to you.
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and
Comms
Necessary for our legitimate interests i.e., to study how customers use our products/
Services, to develop them, to grow our business and to inform our marketing strategy.
To use data analytics to improve our website, products/Services, marketing, customer
relationships and experiences.
(a) Technical
(b) Usage
Necessary for our legitimate interests to define types of customers for our products and
Services, to keep our website updated and relevant, to develop our business and to inform
our marketing strategyNote: Where applicable consent will be used for data analytics obtained through cookies or
similar technologies. See our cookies notice
To make suggestions and recommendations to you about our Services that may be of
interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Comms
Necessary for our legitimate interests to develop our products/ Services and grow our
business
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Marketing communications
Viewtures Limited may send you marketing communication. You have the right to object to
processing of your personal data for direct marketing purposes. You can unsubscribe from
receiving marketing communications from us by using the unsubscribe methods contained in
communications we send to you or by contacting us. See Contact us.
Where you opt out of receiving marketing communications this will not apply to personal data
provided to us as a result of registering for or using our Service, your service experience or
other interactions with this website.
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How we share your personal data
We may have to share your personal data with the parties set out below:
 Internally: Your personal data will be used by our employees and contractors who are
working on providing your Services to you on a need-to-know basis.
 Advertising networks and analytics service providers: We may share the information
that we collect with third parties such as advertisers, contest sponsors, promotional
and marketing partners, and others who provide our content or whose products or
Services we think may interest you. Similarly, we may share portions of our log file
data, including IP addresses, for analytics purposes with third parties such as web
analytics partners, application developers, and ad networks. If your IP address is
shared, it may be used to estimate general location and other technographics such
as connection speed, whether you have visited the website in a shared location, and
type of the device used to visit the website.
These service providers may aggregate information about our advertising and what
you see on the website and then provide auditing, research and reporting for us and
our advertisers.
Context of a sale: We may also share personal data with our current and future
affiliated companies and business partners and if we are involved in a merger, asset
sale or other business reorganization we may also share or transfer personal data to
our successors-in-interest.
 Suppliers for the functioning of our Services: We may engage third-party service
providers to perform functions and provide services to us such as hosting and
maintaining our servers and the website, database storage and management, e-mail
management, storage marketing, credit card processing, customer service and
fulfilling orders for products and Services you may purchase through the website. Law enforcement bodies, regulators and other authorities: We may also disclose
personal data about you to government or law enforcement officials or private parties
as we, in our sole discretion, believe necessary or appropriate in order to respond to
claims, legal process (including subpoenas), to protect our rights and interests or
those of a third party, the safety of the public or any person, to prevent or stop any
illegal, unethical, or legally actionable activity, or to otherwise comply with applicable
court orders, laws, rules and regulations.

International transfers
How we safeguard personal data when we transfer it internationally
We ensure a similar degree of protection is afforded whenever we transfer personal data out
of the UK/EU by ensuring at least one of the following safeguards is implemented:
1. We will only transfer your personal information to countries that have been deemed
to provide an adequate level of protection for personal information; or
2. We will use specific contracts approved for use in the UK/EU which give personal
information the same protection it has in the UK/EU. For example, the use of Article
46 UK/EU GDPR safeguard mechanisms to transfer personal data.
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Data Security
We implement a variety of security measures to maintain the safety of your personal
information when you place an order or enter, submit, or access your personal information.
We offer the use of a secure server. All supplied sensitive/credit information is transmitted
via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway
providers database only to be accessible by those authorized with special access rights to
such systems, and are required to keep the information confidential. We cannot, however,
ensure or warrant the absolute security of any information you transmit to Viewture Limited
or guarantee that your information on the Service may not be accessed, disclosed, altered,
or destroyed by a breach of any of our physical, technical or managerial safeguards.
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Data Retention
Viewture Limited will only retain your personal data for as long as reasonably necessary to
fulfil the purposes we collected it for including for the purposes of satisfying any legal,
regulatory, tax, accounting or reporting requirements. We may retain your personal data for a
longer period in the event of a complaint or if we reasonably believe there is a prospect of
litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information we consider the
amount, nature and sensitivity of the personal information, the potential risk of harm from
unauthorised use or disclosure of your personal information, the purposes for which we
process your personal information and whether we can achieve those purposes through
other means and the applicable legal, regulatory, tax, accounting or other requirements.
Viewture Limited may anonymise your personal data so that it can no longer be associated
with you for research or statistical purposes in which case we may use this information
indefinitely without further notice to you.
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Childrens’ Privacy
We do not address anyone under the age of 13. We do not knowingly collect personal data
from anyone under the age of 13. If you are a parent or guardian and you are aware that
your child has provided us with personal data, please contact us. If we become aware that
we have collected personal data from anyone under the age of 13 without verification of
parental consent, we take steps to remove that information from our servers.
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Data Subject Rights
Under certain circumstances, you have rights under data protection laws. You can:
 Request access to your personal data: This is known as a "data subject access
request" and enables you to receive a copy of the personal data Viewture Limited
hold about you.
 Request correction of your personal data: This enables you to have any
incomplete or inaccurate information we hold about you corrected.
 Request erasure of your personal data: This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process it.
Note: We may not always be able to comply with your request of erasure for specific
legal reasons which will be notified to you at the time of your request.
 Object to processing of your personal data: This is where we are processing your
personal data based on a legitimate interest or those of a third party and you may
challenge this. However, we may be entitled to continue processing your information
based on our legitimate interests or where this is relevant to any legal claims. See
also Marketing communications.
 Request restriction of processing your personal information: This enables you
to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the information's accuracy (b) where our use of the
information is unlawful but you do not want us to erase it (c) where you need us to
hold the information even if we no longer require it as you need it to establish,
exercise or defend legal claims or (d) you have objected to our use of your
information but we need to verify whether we have overriding legitimate grounds to
use it.
 Request transfer of your personal information (“data portability”): This is where
in some circumstances we will provide to you or a third party you have chosen your
personal data in a structured, commonly used, machine-readable format.
 Right to withdraw consent: This is where we are relying on consent to process
your personal data. This will not affect the lawfulness of any processing carried out
before you withdraw your consent. Depending on the processing activity, if you
withdraw your consent we may not be able to provide certain Services to you. We will
advise you if this is the case at the time you withdraw your consent.
 Automated decision making: This is where decisions are made about you by
automated means.We do not carry out automated decision making.
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Keeping personal information accurate and current
It is important that the personal data we hold about you is accurate and current. Please keep
us informed if your personal data changes during your relationship with us. If you wish to
update your personal data please contact us. See Contact us.
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Carrying out your data subject rights
You will not have to pay a fee to access your personal data or to exercise any of the other
rights. However, we may charge a reasonable fee if your request is clearly unfounded,
repetitive or excessive. We may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal information or to exercise
any of your other rights. This is a security measure to ensure that personal information is not
disclosed to any person who has no right to receive it. We may also contact you to ask you
for further information in relation to your request to speed up our response.We try to respondto all legitimate requests within one month. Occasionally it may take us longer than a month
if your request is particularly complex or you have made a number of requests. In this case,
we will notify you and keep you updated.If you wish to exercise any of the rights set out
above, please contact us at info@viewture.com
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Concerns and complaints
We would appreciate the chance to deal with your concerns in the first instance. Please
see Contact us section. If you have unresolved concerns and you live or work in the UK or
believe that a personal data breach happened in the UK you have the right to complain at
any time to the Information Commissioner's Office (ICO), the UK supervisory authority for
data protection issues (www.ico.org.uk).
If you live or work outside the UK or you have a complaint concerning our personal data
processing activities you may lodge a complaint with another supervisory authority.
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Links To Third-Party Services
We may display, include or make available third-party content (including data, information,
applications and other products services) or provide links to third-party websites or services
("Third- Party Services"). You acknowledge and agree that Viewture Limited shall not be
responsible for any Third-Party Services, including their accuracy, completeness, timeliness,
validity, copyright compliance, legality, decency, quality or any other aspect thereof. Viewture
Limited does not assume and shall not have any liability or responsibility to you or any other
person or entity for any Third-Party Services. Third-Party Services and links are provided
solely as a convenience to you and you access and use them entirely at your own risk and
subject to such third parties' terms and conditions.
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Links to Other Websites
This Privacy Policy may contain links to other websites not operated or controlled by
Viewture Limited. We are not responsible for the content, accuracy or opinions expressed in
such websites, and such websites are not investigated, monitored or checked for accuracy
or completeness by us. Please remember that when you use a link to go from our website to
another website, our Privacy Policy is no longer in effect. Your browsing and interaction on
any other website, including those that have a link on our platform, is subject to that
website’s own rules and policies. Such third parties may use their own cookies or other
methods to collect information about you.
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Changes To Our Privacy Policy
We may change our Service and policies, and we may need to make changes to this Privacy
Policy so that they accurately reflect our Service and policies. Unless otherwise required by
law, we will notify you for example, through our Service before we make changes to this
Privacy Policy and give you an opportunity to review them before they go into effect. Then, if
you continue to use the Service, you will be bound by the updated Privacy Policy. If you do
not want to agree to this or any updated Privacy Policy, you can delete your account.

Contact us
If you would like more information about the way we manage personal data that we hold
about you please contact us at:
Email address: info@viewture.com
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Additional Information for California Residents
The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal
Information we collect and how we use it, the categories of sources from whom we collect
Personal Information, and the third parties with whom we share it, which we have explainedabove. Note that under the CCPA we will provide you with this information contained within
the last 12-month period preceding your request.
We are also required to communicate information about rights California residents have
under California law. You may exercise the following specific rights:
 Right to Know and Access: You may submit a verifiable request for information
regarding the: (1) categories of Personal Information we collect, use, or share; (2)
purposes for which categories of Personal Information are collected or used by us;
(3) categories of sources from which we collect Personal Information; and (4) specific
pieces of Personal Information we have collected about you.
 Right to Equal Service: We will not discriminate against you if you exercise your
privacy rights.
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 Right to Delete: You may submit a verifiable request to close your account and we
will delete Personal Information about you that we have collected.
 Non-Sale of Data: Request that a business that sells a consumer's personal data not
sell the consumer's personal data.
We do not sell the Personal Information of our users. If you want us to carry out your rights
please see the section on Carrying out your data subject rights.
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Contact us
If you would like more information about the way we manage personal data that we hold
about you please contact us at:
Email address: info@viewture.com