Data Protection Officer,
Vivo Rewards Limited, 160 Robert Dashwood Way, London, SE17 3PZ, United Kingdom
or email us at email@example.com
Who we are
Vivo Rewards Ltd is a UK base company with company number 07425899.
We are registered as a data controller (Registration number: Z2967637) in accordance with United Kingdom Data Protection Act 1998. We will process any personal information we collect about you in accordance with current data protection laws (currently the Data Protection Act 1998).
Data protection legislation applies to ‘personal data’ (data that relates to a living individual such as a name, home address or mobile telephone number) and regulates how that data is collected, held and processed. Data protection in the UK is governed by the Data Protection Act 1998 (the “DPA”).
For the purposes of the DPA, Vivo Rewards Limited is the ‘data controller’ of the personal data of Vivo users (i.e. the organisation that is responsible for, and controls the processing of, that personal data).
What do the following terms mean?
- “Vivo” means the web based school reward system available at https://www.vivoclass.com.
- “Vivos” mean the electronic credits awarded through Vivo that may be redeemed for products or services offered by our promotions partners.
- The “Website” mean the website located at https://www.vivoclass.com.
- “We”, “us” and “Vivo Rewards” mean Vivo Rewards Limited.
- “You” mean you in your capacity as a registered Vivo user.
What personal data do we process?
We process the following types of personal data about you when you use Vivo:
- Information provided by you. We collect personal data, such as your name and email address, when you register to become a member of Vivo. This information is used when you set up your personal profile. As part of your personal profile, you may choose to submit additional information such as your mobile phone number and your personal email address.
- Information provided by your School. Your school provides Vivo with your name, school email address (if you have one), year group, tutor group and house. Your school also provides Vivo with details of your performance at school. This may include notification of good (or bad) behaviour as well as details of your attendance history. Your school gives us this data so that we can automatically reward (or penalise) you Vivos using the rewards scheme set by your school.
- Information relating to your use of Vivo. We collect and process information relating to your use of Vivo, including details of the number of Vivos in your account, and how you earn and spend your Vivos.
- Information collected automatically. Vivo Rewards receives and stores information which is transmitted automatically from your computer when you browse the Internet and use Vivo. This includes information from cookies (which are described in the section below on Cookies), your IP address and browser type. Your IP address is the unique address of your computer which is automatically provided to other computers when your web browser requests a web page from those computers on the Internet.
How do we use your personal data?
We will use your personal data in order to deliver the Vivo service to you. This includes using your personal data to:
- Manage your Vivo user profile and your Vivos account
- Process your Vivos transactions
- Send you SMS updates on your Vivos account balance, if you have provided us with your mobile phone number and opted in to receive this service
- Deliver a customised Vivo service to you. This may include providing you with customised content that is relevant to your School year group.
We may use your email address to contact you from time to time about our Vivo service and may also use it for security reasons to confirm that you are who you say you are. We also may use the information collected automatically, such as your IP address and information stored via cookies, to gather statistics about the number of people who visit Vivo and to customise its content, layout and services. We may share this information, on an aggregate and anonymised basis, with third parties to help us improve Vivo and better serve our users.
Disclosure to third parties
Our promotions partners have no direct access to your name or personal contact information stored by Vivo. We will only provide your personal data to a promotions partner where necessary in order to carry out a transaction you have made using Vivos.
We may provide your personal data and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing you with the Vivo service. Such third party entities will be obligated to use your personal data solely to provide services to us in connection with the Vivo service, and for no other purpose.
We will disclose your personal data if we reasonably believe we are required to do so by law, regulation or other government authority or to protect the rights and property of Vivo Rewards, its affiliates or the public. We may also co-operate with law enforcement agencies in any official investigation and we may disclose your personal data to the relevant agency or authority in doing so.
We reserve the right to transfer your personal data in the event of a transfer of ownership of Vivo Rewards Ltd, such as acquisition by or merger with another company.
Under the General Data Protection Regulations (GDPR) you have the following rights:
- Information Right – the right to receive the information contained in this policy and our data collection forms about the way we process your personal data.
- Personal Data Access Right – the right to know that we are processing your personal data and, in most circumstances, to have a copy of the personal data of yours that we hold. You can also ask for certain other details such as what purpose we process your data for and how long we hold it.
- Personal Data Correction Right – You have the right to request that we correct inaccurate data or complete incomplete data that we hold on you.
- Personal Data Erasure Right – Known as the Right to be forgotten. In certain circumstances you may request that we erase your personal data held by us.
- Personal Data Restriction Right – You have the right to restrict the way we process your personal data in certain circumstances, for example if you contest the accuracy of the data, if our processing is unlawful, to pursue legal claims, where we are relying on legitimate interests to process data.
- Data Processing Objection Right – You have the right to object to us processing your data for (i) direct marketing purposes (ii) research or statistical purposes and (iii) purposes of profiling related to direct marketing or based on our legitimate interests.
- Data Portability Right – you have the right to receive a copy of certain personal data or to have it transferred to another organisation in some circumstances.
Right to Withdraw Consent at any time
Where we use your personal information based on your prior consent, such as where you have given us permission to send you marketing communications by email, mobile messaging or by direct message on social media, you can withdraw your consent at any time by contacting us.
Right to complain to the Information Commissioner's Office (ICO)
You have the right to be confident that Vivo handles your personal information responsibly and in line with good practice.
If you have a concern about the way we are handling your information, then in the first instance you should raise this with us. We will take your concern seriously and work with you to try to resolve it. However if you are still unhappy with our response you can raise a concern with the ICO, the UK data protection regulator - see the links below for details:ico.org.uk/for-the-public/raising-concerns
Links to other sites
This Website may contain links to other websites that are not owned or controlled by Vivo Rewards Ltd. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage you to be aware when you leave our Website and to read the privacy statements on the other websites that you visit.
When someone visits our website we collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of our website. We collect this information in a way which does not identify anyone.
We use Google Analytics to help analyse use of our Website. This analytical tool uses ‘cookies’, which are text files placed on your computer, to collect standard internet log information and visitor behaviour information in an anonymous form. The information generated by the cookie about your use of the Website (including your IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the Website and to compile statistical reports on Website activity for us.
We will not (and will not allow any third party) to use the statistical analytics tool to track or to collect any personally identifiable information of visitors to our Website.
Further information about cookies
The Interactive Advertising Bureau (IAB) is an industry body that develops standards and guidelines to support online business processes. It has produced a website (www.allaboutcookies.org) which explains how cookies work and how they can be managed.
Disabling and enabling cookies
You have the ability to accept or decline cookies by modifying the settings on your internet browser. The IAB website tells you how to remove cookies from your browser. However, please note you may not be able to take full advantage of the functionality of Vivo or the Website if you do so.
Security and confidentiality
The security of your personal data depends on your protection of your account password. Please do not disclose your account password to unauthorised people.
Vivo uses industry standard technology designed to help keep your personal data safe. We use a 2048-bit SSL certificate for encryption as recommended by The National Institute of Standards and Technology (NIST) of the US Government. Please bear in mind though, that it is impossible for Vivo Rewards to guarantee that impenetrable security measures are in place.
For example, we cannot control any illegal and/or unforeseen activity of other users that may allow them to get around the privacy or security settings on the Website. Consequently, you acknowledge that there are circumstances in which your personal data may be accessed by unauthorised persons.
Vivo Rewards will also take appropriate organisational and security measures to safeguard your personal data against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Our objective is to protect your personal data as follows:
- All of Vivo Reward’s systems, hardware and software used in relation to your personal data are kept secure in accordance with standard industry practice
- All Vivo Rewards employees, contractors and third party service providers are informed of their obligations under the DPA and the restrictions in place on their use of the personal data.