Privacy Policy
OVERVIEW
We promise respectful treatment of the personal information of everyone we have contact with.
This policy explains how we do that – when and why we collect information, how we use it, the situations when other people can see or use it, and how we keep it secure. In summary, we do not sell, rent or trade your data with anyone else.
When you agree to purchase our services, we ask for data such as your name, contact details and billing address. We keep a record of this information for tax purposes and for ensuring we fulfil our contract with you. Whoever you are, our intention is to use your information to make things work smoothly for you in your experience of working with us. If that’s not how it turns out for you, please make sure to contact us at info@librava.co.uk. We keep this policy under regular review, and we may revise it as time goes on. Please check back here from time to time to make sure you have the latest information.
This policy adheres to the guidance set out by the Data Protection Act 2018.
WHO IS HOLDING YOUR DATA?
Name: Libra VA Services Ltd.
Company Registration Number: 13030412
Registered Office Address: 86-90 Paul Street, London, EC2A 4NE
Email Address: info@librava.co.uk
Card and Payment Processor (third parties and their security policy links): Freshbooks and Starling Bank.
Third parties we share information with: associates, suppliers or for software storage purposes.
Our data regulator contact details are: Information Commissioners Office (ICO).
POLICY KEY DEFINITIONS:
“I”, “our”, “us”, or “we” refer to the Company, Libra VA Services Ltd.
“You”, “the user” refer to the person(s) using this website/our service.
“Service” means any and all services provided by Libra VA Services, including, but not limited to, information provided on librava.co.uk.
“Personal Information” means any information relating to an identified or identifiable natural person. This can include name, email address, billing address, and much more.
WHAT DO WE USE YOUR DATA FOR?
The only personal information we hold is what individuals provide us with when they sign up for our newsletter or sign a contract. We may be asked to reply to queries or complaints on behalf of clients. We use data to develop and manage our business relationships in order to help grow our business and fulfil our contracts, to provide services to clients and to calculate payments to associates or affiliates. We share it with nobody, however, it is stored on relevant systems such as Mailchimp (if consent given) and FreshBooks (invoice and tax purposes). If we are required by law to share any information, we will check with each party concerned to ensure they are happy for that to happen. An example of this would be if HMRC requested an audit.
HOW LONG DO WE KEEP YOUR DATA FOR?
All data is held for only as long as necessary. We store sensitive data for as long as projects are in progress, and up to 28 days afterwards. Email addresses provided via Mailchimp are stored until consent is withdrawn - reconsent is requested every 2 years. Information required for tax and legal requirements is held for 6 years as is required by law. If you subscribed to our newsletter, you will remain on the mailing list until you unsubscribe.
We keep a record of any e-mail communication you send us, so we can track any problems or concerns you have had.
In addition to personal information, our website uses Google Analytics to ensure we are meeting our clients' needs. Google Analytics stores usage data which may include your IP address, geographical location, referral source, length of visit and page views - much of this is aggregated data. The legal basis for this is legitimate interest for the basis of ensuring we are meeting our clients' needs.
HOW WE PROTECT YOUR DATA
Since the Internet is not a 100% secure platform for communication, we cannot guarantee the security of any data you send to us (or we send to you). We are not responsible for any damages which you, or others, may suffer as a result of the loss of confidentiality of such information.
DATA PLATFORMS
We take every precaution to safeguard your information. All personal data stored by us is kept on a server in a secure environment. The computer on which work is conducted on is encrypted and password protected, data held in the Cloud is password protected and held on encrypted systems and third-party software (such as Mailchimp and FreshBooks) have their own security systems.
Like most small businesses, we do not have any tailor-made software – we use mainstream packages for everything from our client records, to email, to accounting. This means that some of your data may be held in the EEA, and some may be held in services in the USA (with suitable data privacy shields) or elsewhere. We have picked mainstream suppliers with appropriate security standards.
The risks of a breach are minimal due to the precautions mentioned above being taken, and close monitoring is undertaken to ensure security systems are always up to date. Breaches will be identified, reported, managed, and resolved according to the ICO guidelines.
CATEGORIES OF DATA
DOWNLOADS, NEWSLETTERS AND SERVICES
We monitor your engagement in our newsletters. We do this so we can see if content is popular and we will generate more (or less) of it depending on engagement. You can remove your information from this monitoring by disabling cookies on your website browser before opening emails from us.
There may be sub-routines that trigger if you click on links or articles. These are designed to offer you more information about the topics you are interested in. You can unsubscribe from these at any time. Existing clients may receive emails about specific offers relating to services you have already purchased. You can unsubscribe from these at any time.
From time to time, we may contact individual email newsletter subscribers, but it is extremely rare.
We use anonymised data about you from time to time to target marketing campaigns based on profiling the sort of person who wants to receive information from us.
We will occasionally contact prospects. This is usually because you have requested a call, or because we are actively trying to let you know about something you may benefit from.
We do not contact individuals who have not previously shown interest in our services - we prefer to build long-term relationships with satisfied clients.
SOCIAL MEDIA
We have an active presence on social media. If you are using social media, these sites are holding and using your information in accordance with their data privacy policy.
If you ‘like’ any of our posts, ‘follow’ us, or contact us on social media we keep a record of that. Your replies to us, messages you send us, and your other activity linked to our posts may be seen by members of our staff and by our associates. Our contracts with them hold them to high standards of protecting your information.
COOKIES
Our website uses cookies to collect information and to deliver the best possible user experience. The data we collect through these cookies is solely for the purpose of improving our website and your browsing experience – it is never used to identify you and we would never share or sell on this data.
You have the option to either accept or refuse these cookies, and know when a cookie is being sent to your computer. Please note that if you choose to refuse our cookies, you may not be able to use some parts of our website.
NO SALE OR EXCHANGE OF YOUR DATA
We do not sell or exchange your personal data with organisations who may want to sell you something or use your data for research or other purposes.
WE MAY SHARE SOME OF YOUR PERSONAL INFORMATION WITH THESE PROVIDERS
We may employ third-party companies and individuals due to the following reasons:
To facilitate our service;
To provide the service on our behalf;
To perform service-related services; or
To assist us in analysing how our service is used.
We want to inform our service users that these third parties have access to your personal information. The reason is to perform the tasks assigned to them on our behalf. Third-party companies and individuals are governed by our Terms and Conditions and Privacy Policy; they are obligated not to disclose or use the information for any other purpose other than that as directed by us.
REQUESTING YOUR INFORMATION
If you would like to review the data you have provided to us because you feel that what we presently have on record is incorrect, and/or you would like your data erased from our records, you can so do by contacting us with your name and email address: info@librava.co.uk. You have a "right to be forgotten" - but that does have some legal limits to it. If you have been a client, we may not be able to remove all data as we will have to ensure that we can continue to comply with legal, accounting, taxation and our insurer’s requirements.
We may require you to confirm your identity before proceeding. Provided we can legitimately disclose the information to you, we will do a search and send you screenshots of what we have. We are more than happy to comply with this in accordance with the law.
Under the Data Protection Act 2018, you have the right to withdraw your consent, to change information we hold about you, and to restrict processing. Most of the information we hold is not based on your individual consent but is based on us requiring the information to run our business and provide our services.
OUR LEGAL BASIS FOR PROCESSING YOUR DATA
MARKETING MATERIAL
If you are happy to receive marketing communications by email, you may sign up for our newsletter. This means you will receive monthly marketing updates including tips and advice. You may unsubscribe at any time. We will never spam you or sell your email address to third parties.
PROSPECTS
You are not automatically subscribed to our mailing list but may be invited to sign up. If we email you individually or respond to an email sent to us at any of our business email addresses, a copy of that email will also be stored. If you make an enquiry via our website, we will keep details of that enquiry and response for our data retention period. We do not routinely keep special category data. To the extent we hold this, it was supplied or made publicly available by you.
CLIENTS
Once you hire our services, we will collect information from you at the point of sale.
This will include the information we collect from prospects (above). We collect your email address, phone number and billing address so we can provide what we have contracted to, invoice you and keep proper records of our business relationship.
We process your data to support the delivery of the services you have hired. We keep records of the services provided to you, and the information you provide us with, so we can support you when needed and advise you of any additional services you may need.
THIRD PARTY DATA
As well as your own personal data, we understand that you may need to provide us with personal data relating to your employees, your workers, or third parties (often your clients or suppliers) – depending on the services we are providing to you. We hold all such information under strict confidentiality obligations, as set out in our terms of business.
THIRD PARTY INFORMATION
We will act in accordance with your statutory rights, subject to the exclusions and exemptions that may apply.
When we are processing data about you on behalf of a client, we are operating under the banner of our client’s data privacy policy. We will refer any enquiry from you to them, as they are the ‘data controller’ responsible for dealing with your query. We will support that by providing relevant information to our client for passing to you.
When we are processing data about you because of a direct connection between you and our business we are acting as a ‘data controller’ (and operating under this policy).
SUPPLIERS, ASSOCIATES AND AFFILIATES
If you become a supplier, associate or an affiliate/referrer we keep a copy of the contract between us and your bank details so we can pay you. We also keep a record of invoices/payments for accounting purposes.
We keep a record of the work you undertook for us/our clients along with any comments, reviews or suggestions about that work including complaints (if any) and their resolution.
This information is required to manage our client relationships and our supply chain.
If we set up an affiliate/referrer scheme, affiliate/referrer data will be held in accordance with this policy. We will ask you for information when you apply, and that information will be kept to administer the scheme.
If you are a referrer, we remind you that any referrals that you make to us may only be made with the knowledge and consent of the person being referred.
FINANCIAL AND CREDIT CARD DETAILS
Credit card payments are handled by an external secure processor in accordance with their data security policies. We receive limited information from our processor for us to tie up your payment with your invoice.
If you pay us by BACS or direct transfer, we know only what the bank tells us - the payee name, the amount, and the reference number.
We do not routinely keep credit scores nor use credit reference agencies.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to amend our Privacy Policy, whilst keeping it within all appropriate legislation and guidelines. We will do all we can to ensure that these pages show the most up to date information at all times, and will notify you of such changes by uploading the revised Privacy Policy on our website.
CONTACT US
If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us: info@librava.co.uk.
If we can’t sort it out, the relevant supervisory authority details can be found on the form above.
Updated March 2023.