Privacy Policy

This privacy policy aims to give you information on how Verse Digital collects and processes your personal data through your use of this website, including any data you may provide through this website, when you sign up to our newsletter, purchase a product or service from us, take part in a competition or otherwise interact with us by any other means.

In accordance with the UK Data Protection Act 2018 and Children’s Online Privacy Protection Act (“COPPA”), we do not knowingly request, solicit or access personally identifiable information from anyone under the age of 13 or, in respect of other jurisdictions under the applicable age limit, if higher. Our partners who use our services to provide advertising media for customers and store personal data may, however, collect personal data from individuals under the age of 13 (or other applicable age). Such partners are the “operators” of the respective media (as defined by COPPA) or “controllers” as defined by the Data Protection Act 2018 or GDPR. While it is our partners’ responsibility, not ours, to ensure compliance with COPPA or other applicable data protection laws in relation to the collection of such data, in the event we have actual notice that a partner has collected personal information in violation of COPPA, Data Protection Act 2018 or other applicable law, we will require such partner to take measure to comply with the applicable legislation.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and is not intended to override them.

Verse Digital is the controller and responsible for your personal data (collectively referred to as ”COMPANY”, “we”, “us” or “our” in this privacy policy) and this privacy policy is issued on behalf of Verse Digital.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact Details

Full name of legal entity: Verse Digital Limited

Name of data privacy manager: Justin Edwards

Email address: justin@versedigital.org

Postal address: 8 Wellington Court, Cambridge, England, CB1 1HZ

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes To The Privacy Policy And Your Duty To Inform Us Of Changes

Please check our privacy policy on our website from time to time as we may make changes to it to reflect the changes which we make to our practices in order to keep up to date with industry requirements and recommended practices.

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes the personal data you provide when you:

– apply for our products or services;
– create an account on our website;
– subscribe to our service or publications;
– request marketing to be sent to you;
– enter a competition, promotion or survey; or
– give us some feedback

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies or use a third-party app that uses our advertising platform.

Third parties or publicly available sources. We may receive personal data about you from various third parties:

Technical Data from the following parties:

(a) analytics providers such as Google based outside the UK;

(b) advertising networks such as Verizon based outside the EU; and other networks outside the UK

(c) search information providers such as Google based outside the UK.

(d) location (country, longitude, and latitude), user ID and device ID where this is sent to us by our partners in connection with services we are providing them;

Contact, Financial and Transaction Data from providers of technical, payment, and delivery services such as Tipalti based outside the UK.

Identity and Contact Data from data brokers or aggregators such as Integral Ad Science-based outside the UK.

Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you or a third party that you have contracted with.

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.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes For Which We Will Use Your Personal Data

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.

Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you feel any content is inappropriate do contact us.

Promotional Offers From Us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any company external to Verse Digital for marketing purposes.

Opting Out
You can ask us or third parties to stop sending you marketing messages at any time contacting them through the applicable app, by email or through their website to notify them of your opt-out request Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions directly with us.

Cookies
You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change Of Purpose
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for for our business purposes, as follows:

Internal Third Parties such as our data analytics team

External Third Parties such as our media partners and service providers

Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We share data only to the extent necessary to provide the services to you, perform the contract, to comply with law or as necessary in connection with the purpose for which the data was collected or received. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. All these third parties are required to keep the information confidential and secure and to undergo regular training in relation to compliance with data protection legislation and principles.

We will not sell your personal data and have not sold it in the previous 12 months.

We share your personal data within the Company, solely based in the UK.

For further information on the specific instances and the mechanisms by which we might need to transfer your personal data out of the UK, please contact us.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we 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.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

– Request access to your personal data
– Request correction of your personal data
– Request erasure of your personal data
– Object to processing of your personal data
– Request restriction of processing your personal data
– Request transfer of your personal data
– Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third Parties

External Third Parties

Service providers acting as processors based sometimes outside the EU who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based sometimes outside the UK who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Your Legal Rights

You have the right to:

– Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

– Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

– 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 to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

– Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

– Request restriction of processing of your personal data. 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 data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data 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 data but we need to verify whether we have overriding legitimate grounds to use it.

– Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

– Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.