Vuelio, ResponseSource & Pulsar are technology companies headquartered in The Johnson Building, 79 Hatton Garden, London, London EC1N 8AW, United Kingdom, email: [email protected], phone: 0203 426 4070,
- Access Intelligence Media and Communications Ltd (AIMC) / AI Media Data Ltd (AIMD) trading as “Vuelio”
- ResponseSource Ltd trading as “ResponseSource”
- Fenix Media Ltd trading as “Pulsar”
- the use of https://www.vuelio.com/ and https://www.responsesource.com/ (“Websites”)
- the use of our products and services, available via our Websites sub-domains (“Applications”)
- social media messages and marketing campaigns
- A Website visitor
- An influencer e.g. journalist, subject/domain expert, blogger, politician etc.
- An end-user of the application
- A prospective client
- A job applicant
- Partners and suppliers
- An influencer e.g. journalist, subject/domain expert, blogger, politician etc.
- Non-influencer privacy information for Pulsar can be found here: https://www.pulsarplatform.com/privacy-policy/
We ensure that we use your information in accordance with all applicable laws concerning the protection of your personal data (“Data Protection Law”).
WHO WE ARE:
Vuelio and ResponseSource are part of Access Intelligence – a tech innovator, delivering high quality SaaS products that address the fundamental business needs of more than 3,000 global brands in the PR, communications and marketing industries.
For more information about Access Intelligence, Vuelio and ResponseSource, please see the “About Us” sections of our Websites:
INFORMATION WE COLLECT:
We may collect and process the following personal information about you, depending on how you interact with us:
- End users of the application, customers and prospective clients – we will collect your personal data in order to contact you and provide you with access to the Services e.g. name and email address
- Partners and Suppliers – we may collect your personal data in order to communicate with you and manage our account with your company
- Job applicants – we will collect any personal details which you submit in order for us to process your application
- Website visitors – we may collect personal data, usage data and/or analytical data e.g. IP address, website usage data
- Influencers (e.g. journalists, subject/domain experts, bloggers, politicians etc.) – we may collect the following personal information about you:
- Prefix and name
- Job title & place of work
- Biographical information
- Work history
- Education history
- Telephone number
- Postal address
- Work email address
- Twitter ID
- Twitter handle
- Twitter biography
- Twitter profile image
- LinkedIn profile URL
- Other social media profiles
- Other publicly available social media content
- Communication preference
- Geolocation data
This information is either collected voluntarily from you, automatically or obtained from a third-party source:
- Information that you provide voluntarily
- Certain parts of our Websites may ask you to provide personal information voluntarily. For example, we may ask you to provide your contact and company details in order to assist you with any questions or requests you submit to us regarding our software or services. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information, but this might include your name and business contact information to enable us to respond with service options relevant to your business.
- If you contact us using the forms or contact details on our Websites, or by emailing individual Access Intelligence employees, we will collect a copy of that correspondence.
- If you are an Authorised User of the Services, we will collect the details that you provide in order to create an account to access our software in connection with your employer’s service subscription.
- We may also ask you to complete surveys that we use to help us improve our software and services, although you do not have to respond to them.
- Influencers will also be contacted directly by our Research team to provide or validate the contents of our Databases, as described below.
- Information that we collect automatically
- When you visit our Websites, or use our software including our Databases, we may collect certain information automatically from your device.
- Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Website or software, including the pages accessed and links clicked.
- Collecting this information enables us to better understand the visitors and users, where they come from, and what content on our Website or Databases or other software is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors.
- Some of this information may be collected using cookies and similar tracking technology (collectively, “Cookies”). For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie
- Information we obtain from third party sources
- Contact enrichment and lead generation providers.
- If you are an Influencer, we may collect information about you for the purposes of adding you to our Databases. The third-party sources that we will collect your information from public sources such as LinkedIn pages and other social media, newspapers or other publications that you are published in and/or any other public profiles that you maintain for professional purposes.
- Specifically, the information we will collect from these third party sources may include information like your name, photographs and other images of you and professional contact details (or social media handles), your educational history, industries and/or subject matters that you communicate about, historical publications and/or your professional/employment history as well as any other information about you relating to your profession. We collect this information to maintain and improve the accuracy of your listing and profile on our Databases, as is more particularly described in the “Legal Basis” section of this Privacy Notice below.
INFORMATION WE DON’T COLLECT:
Our Services are directed to working professionals. Our Services are not intended for children under 16 years of age, and we do not knowingly collect personal information from children under that age.
HOW WE USE YOUR INFORMATION:
We will use the information that we collect about you for the following purposes:
- Providing our services
- Research and analytics
- Marketing and communications
- Administration info
- Managing customer order
- Managing user account
- Customer feedback collection
- Site protection
- Support services
- Legal compliance
If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.
HOW WE SHARE YOUR INFORMATION:
We may disclose your personal information to the following categories of recipients:
- Customers – If you are an Influencer, we may share information about you contained in our Databases with customers of our Services. Customers are subject to our Acceptable Use Policy.
- Suppliers – A list of our processors and sub-processors is available at: https://www.accessintelligence.com/trustcentre/sub-processors/
- Group companies – data may be shared between other companies in the Access Intelligence group.
We require such third parties to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose.
Vuelio and ResponseSource are hosted in the UK. Some of our external third parties are based outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that we use specific contracts approved by the Information Commissioners Office (ICO) and European Commission (EC) which give personal data the same protection it has in the UK and Europe.
The destination country may have been granted an adequacy decision by the EC, otherwise we will secure Standard Contractual Clauses (SCCs) or International Data Transfer Agreement (IDTA) with the third-party, in accordance with Data Protection Law.
RETENTION OF YOUR INFORMATION:
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, for as long as necessary to provide you or your employer with access to our software or services, to maintain your profile as an Influencer on our Databases, to keep in contact with you about our Services or to comply with applicable legal, tax or accounting requirements. Where you are an Influencer, we will retain your personal information until either (a) you request us to cease processing such information in accordance with your data protection rights or (b) you cease to be professionally active for a significant period of time.
We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.
The security of your information is important to us, and we are committed to protecting the security of all of the personal information we process.
We use a variety of physical, administrative and technical safeguards designed to help protect it from unauthorised access, use and disclosure. We have implemented best-practice standards and controls in compliance with internationally recognised security frameworks. We use encryption technologies to protect data at rest and in transit.
Information within Access Intelligence is governed by a management system which has been certified as ISO 9001 and ISO 27001 compliant. For more details, please refer to our Trust Centre.
DATA CONTROLLER OR PROCESSOR?
Certain Data Protection Laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller”, who determines the purposes and means of processing; and the “Data Processor”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
We are the “Data Controller” of website visitors, customers and prospective customers personal data. Additionally, we are the Data Controller for any Influencer personal data contained in our Databases.
Any private data or content uploaded by our Customers shall be processed by us on behalf of the Customer, subject to our commercial agreements. Such Customer shall be deemed the “Data Controller” with respect to this content and Vuelio/ResponseSource will process such data on this Customer’s behalf, as its “Data Processor”. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only: (i) where the processing is in our legitimate interests and not overridden by your rights; or (ii) where we have your consent to do so.
We collect and use your personal information on the basis of our legitimate interests (or those of any third party) in connection with:
- our operation of our Websites (for example we collect information about usage and engagement with our Website to improve its functionality, personalisation and security);
- our provision of Services and communicating with you or our customers as necessary to provide our Services;
- responding to any queries that you submit to us;
- undertaking marketing of our Databases and/or other services to relevant decision makers through targeted campaigns;
- detecting or preventing illegal activities; and
- (if you are an Influencer) our using your information for the purposes of:
- (i) compiling and maintaining our Databases, to ensure our customers have access to the most comprehensive and up-to-date information and thereby ensure they engage with Influencers in ways that are relevant, timely and targeted;
- (ii) providing you with marketing information, regular news bulletins and other information which we consider you find useful, interesting and/or of relevance to your role as an Influencer;
- (iii) referring your personal information to customers of our Databases, public relations and marketing professionals, public relations agencies and corporate press offices and other users of our services when you make an enquiry through our enquiry service; and
- (iv) providing you with newsletters containing regular news bulletins, details regarding our products and services, latest blog content, industry news and any other information related to or otherwise connected with the above.
We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are. Where we do process your information on the basis of our legitimate interests, we will consider any consequences or impact it may have on you and will not rely on legitimate interests grounds if we think that our interests are outweighed by any negative impact the activities may have on you.
Depending on the law that applies, you may have a right to access and rectify or erase your personal data or receive a copy of your personal data, restrict or object to the active processing of your data, ask us to share (port) your personal information to another entity, withdraw any consent you provided to us to process your data, a right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us at [email protected]. We will respond to your request in accordance with applicable law.
You may opt-out of direct marketing communications by clicking on the “unsubscribe” link at the bottom of the marketing email that we sent you or by writing to us at [email protected].
Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the Services for which your information was sought.
GRIEVANCE / DATA PROTECTION OFFICER:
If you have any queries or concerns about the processing of your information that is available with us, you may contact us using the following details depending on your geographic region:
The Johnson Building,
79 Hatton Garden,
London, EC1N 8AW
Instant EU GDPR Representative Ltd
69 Esker Woods Drive,
If you remain unsatisfied by our response, you may contact the Information Commissioners (ICO) offices at the following address:
Information Commissioner’s Office