Introduction
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. We do so as a consequence of us providing our services to you as a Customer or where we engage you as a Model or a Creator to provide services to us, or where you use our website as a User (capitalised terms are defined in the Key Terms table below).
We keep our privacy policy under regular review. This version was last updated on 29th June 2023.
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.
We collect, use and are responsible for certain personal data about you. We do so as a consequence of us providing our services to you as a Customer or where we engage you as a Model or a Creator to provide services to us, or where you use our website as a User (capitalised terms are defined in the Key Terms table below).
We keep our privacy policy under regular review. This version was last updated on 29th June 2023.
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.
Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit
Key Terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our: Visaura Ltd, 53 The Parade, Roath, Cardiff, CF24 3AB
Our data protection officer: ryan@visaura.com
Personal data: Any information relating to an identified or identifiable individual
Special Category Data: Personal data revealing gender, racial or ethnic origin, religious beliefs, philosophical beliefs, health, sexual orientation, or trade union membership. Data concerning health, sex life or sexual orientation
Data subject: The individual who the Personal Data relates to, for the purposes of this policy can be Customers, Models, Creators or Users.
Customer: Individual who engages us to provide services, or representative of a corporate entity that engages us to provide services
Model: Individual engaged either directly or through an agency for their image to be used in Content
Creator: Individual or entity engaged either directly or through an agency to produce Content
User: Individual user or browser of www.auraads.co.uk
Content: Advertising material created for our Customers
You, your: Data Subject who this policy applies to
We, us, our: Visaura Ltd, 53 The Parade, Roath, Cardiff, CF24 3AB
Our data protection officer: ryan@visaura.com
Personal data: Any information relating to an identified or identifiable individual
Special Category Data: Personal data revealing gender, racial or ethnic origin, religious beliefs, philosophical beliefs, health, sexual orientation, or trade union membership. Data concerning health, sex life or sexual orientation
Data subject: The individual who the Personal Data relates to, for the purposes of this policy can be Customers, Models, Creators or Users.
Customer: Individual who engages us to provide services, or representative of a corporate entity that engages us to provide services
Model: Individual engaged either directly or through an agency for their image to be used in Content
Creator: Individual or entity engaged either directly or through an agency to produce Content
User: Individual user or browser of www.auraads.co.uk
Content: Advertising material created for our Customers
You, your: Data Subject who this policy applies to
Personal data we collect about you
We may collect a variety of information about you depending on what the status of our relationship with you is. We have summarised the different kinds of Personal Data collected for each of the categories of Data Subject that this policy applies to:
1. Customers:
1. Customers:
- Identity Data: includes full name.
- Contact Data: includes email address and telephone number and company details where applicable, online presence.
- Financial Data: includes: billing information, transaction and payment card information
- Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.
- Marketing Data: includes your preferences in receiving marketing communications from us or third parties.
- Profile Data: feedback, and your responses to surveys, competitions and promotions, your contact history, purchase history and saved items.
- Usage Data: information about how you use our services, our website, IT, communication and other systems.
2. Models and Creators:
- Identity Data: includes full name, date of birth, pronouns.
- Contact Data: includes email address and telephone number, delivery address, billing address, agency details where applicable, online presence/social media handles.
- Assignment Data: includes eligibility to work, criminal convictions, photos, videos, languages spoken, skills, height, clothing size, dietary requirements, access requirements, details of pets, details of home, photos of home.
- Special Category Data: includes information about your gender, racial or ethnic origin, religious or philosophical beliefs, information concerning your health or sexual orientation, or trade union membership.
- Financial Data includes bank account information.
3. Users:
- Technical Data: includes your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, the device type, operating system, unique device identifiers, device settings, and geo-location data.
- Usage Data: information about how you use our services, our website, IT, communication and other systems.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you, or engaging you as either a Model or a Creator.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you, or engaging you as either a Model or a Creator.
How your personal data is collected
We collect most of this personal data directly from you in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:
- from publicly accessible sources, eg Companies House;
- directly from a third party, eg: customer due diligence providers, LinkedIn, insofar as Models or Creators are concerned we may collect information from your agency.
- from cookies on our website—for more information on our use of cookies, please see our cookie policy
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a lawful basis eg:
- where you have given consent;
- to comply with our legal and regulatory obligations;
- for the performance of a contract with you or to take steps at your request before entering into a contract; or
- for our legitimate interests or those of a third party.
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why:
The table below explains what we use your personal data for and why:
Lawful basis
What we use your personal data for
Type of data
Providing services to you as a Customer
To perform our contract with you or to take steps at your request before entering into a contract
Identity
Contact
Financial
Marketing
Contact
Financial
Marketing
Engagin you as a Model/Creator
To perform our contract with you or to take steps at your request before entering into a contract
For our legitimate interest, i.e. to provide services to our Customers
Where you have given your express consent.
For our legitimate interest, i.e. to provide services to our Customers
Where you have given your express consent.
Identity
Contact
Assignment
Special Category Data
Financial
Contact
Assignment
Special Category Data
Financial
Managing our relationship with you
To perform our contract with you or to take steps at your request before entering into a contract
For our legitimate interest, i.e. to provide services to our Customers
To comply with our legal and regulatory obligations.
For our legitimate interest, i.e. to provide services to our Customers
To comply with our legal and regulatory obligations.
Identity
Contact
Profile
Assignment Marketing
Contact
Profile
Assignment Marketing
Preventing and detecting fraud against you or us
For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us
Identity
Contact
Financial
Contact
Financial
To enforce legal rights or defend or undertake legal proceedings, or to provide information required relating to audits, enquiries or investigations by regulatory bodies.
To comply with our legal and regulatory obligations;
For our legitimate interests, i.e. to protect our business, interests and rights
To comply with our legal and regulatory obligations
For our legitimate interests, i.e. to protect our business, interests and rights
To comply with our legal and regulatory obligations
Identity
Contact
Profile
Financial
Special Category Data
Contact
Profile
Financial
Special Category Data
Operational reasons, such as improving efficiency, training quality control and security of our website.
For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Identity
Contact
Technical
Usage
Contact
Technical
Usage
Statistical analysis to help us manage our business
For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Technical
Usage
Usage
Marketing our services and those of selected third parties to, including sending our newsletter to you:
- existing and former (corporate) customers;
- third parties who have previously expressed and interest in our services;
- third parties with whom we have had no previous dealings.
- existing and former (corporate) customers;
- third parties who have previously expressed and interest in our services;
- third parties with whom we have had no previous dealings.
For our legitimate interests, i.e. to promote our business to existing and former (corporate) customers.
Consent where applicable.
Consent where applicable.
Identity
Contact
Technical
Usage
Marketing
Contact
Technical
Usage
Marketing
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services or to send your our newsletter.
We have a legitimate interest in using your personal data for marketing purposes (see table above). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
We have a legitimate interest in using your personal data for marketing purposes (see table above). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
- You have the right to opt out of receiving marketing communications at any time by using the ‘unsubscribe’ link in emails.
We will always treat your personal data with the utmost respect and never sell it to other organisations for marketing purposes.
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. For more information about the cookies we use please see our cookie policy
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services, eg payment service providers and delivery companies;
- other third parties we use to help us run our business, eg marketing agencies or website hosts and IT and systems administrators;
- third parties approved by you, eg social media sites you choose to link your account to or third party payment providers;
- in some instances we will share Creator Personal Data (such as name and address) with our Customers, so that their products can be used in the production of Content;
- our bank.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
We or the third parties mentioned above occasionally also share personal data with:
- our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations;
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations;
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations;
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Where your personal data is held
Personal data may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above.
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below.
Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal data when this happens, see below.
How long your personal data will be kept
We 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 data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Please contact us if you want further information about how long we will retain your personal data.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Please contact us if you want further information about how long we will retain your personal data.
Transferring your personal data out of the UK
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
- Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
Your rights
You have the following rights, which you can exercise free of charge:
Access
The right to be provided with a copy of your personal data
Rectification
The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data-in certain situations
Restriction of processing
The right to require us to restrict processing of your personal data in certain circumstances, e.g if you contest the accuracy of the data
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party-in certain situations
To object
The right to object:
- at any time to your personal data being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal data, e.g processing carried our for the purpose of our legitimate interests unless thereare compelling legitimate ground for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
- at any time to your personal data being processed for direct marketing (including profiling);
in certain other situations to our continued processing of your personal data, e.g processing carried our for the purpose of our legitimate interests unless thereare compelling legitimate ground for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims
Not to be subject to automated individual decision making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents
If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time
You may withdraw consents by [insert details as relevant depending on consents]
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
You may withdraw consents by [insert details as relevant depending on consents]
Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn
For more information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.
If you would like to exercise any of those rights, please:
If you would like to exercise any of those rights, please:
- Email: ryan@visaura.com;
- provide enough information to identify yourself and any additional identity information we may reasonably request from you; and
- let us know what right you want to exercise and the information to which your request relates.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data. We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner, who may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
You also have the right to lodge a complaint with the Information Commissioner, who may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this policy
We keep our privacy policy under regular review. This version was last updated on 29th June 2023
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