Last updated: 15 May 2019.
Policy key definitions:
• "I", "our", "us", or "we" refer to the business, Verve Rally & Verve Global Ltd.
• "you", "the user" refer to the person(s) using this website.
• "GDPR" means General Data Protection Act.
• "PECR" means Privacy & Electronic Communications Regulation.
• "ICO" means Information Commissioner's Office.
• "Personal Data" means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• "Usage Data" is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• "Data Processors (or Service Providers)" means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
• "Data Subject (or User)" is any living individual who is using our Service and is the subject of Personal Data.
• "Cookies" mean small files stored on a users computer or device.
Key principles of GDPR:
We are registered with the ICO under the Data Protection Register, our registration number is: ZA504269.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Company name and job title/designation
• Dietary preferences
• The make & model of the vehicle you wish to drive on one of our rallies
• Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may also collect information on how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service, to improve and customise our Service. You can enable or disable location services when you use our Service at any time by way of your device settings.
Tracking & Cookies Data
Examples of Cookies we use:
• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Security Cookies. We use Security Cookies for security purposes.
Use of Data
Verve Global Ltd uses the collected data for various purposes:
• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
We control and / or process any personal information about you electronically using the following lawful bases.
• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it is not overridden by your rights
• To comply with the law
Email marketing messages & subscription
Under the GDPR we use the consent lawful basis for anyone subscribing to our newsletter or marketing mailing list. We only collect certain data about you, as detailed in the "Processing of your personal data" above. Any email marketing messages we send are done so through an EMS, email marketing service provider. An EMS is a third party service provider of software / applications that allows marketers to send out email marketing campaigns to a list of users.
Email marketing messages that we send may contain tracking beacons / tracked clickable links or similar server technologies in order to track subscriber activity within email marketing messages. Where used, such marketing messages may record a range of data such as; times, dates, I.P addresses, opens, clicks, forwards, geographic and demographic data. Such data, within its limitations will show the activity each subscriber made for that email campaign.
Any email marketing messages we send are in accordance with the GDPR and the PECR. We provide you with an easy method to withdraw your consent (unsubscribe) or manage your preferences / the information we hold about you at any time. All marketing messages include an unsubscribe link at the bottom of the email that will remove you from receiving future marketing messages.
Our EMS provider is: ActiveCampaign.
Retention of Data
Transfer of Data
Disclosure of Data
Disclosure of Law Enforcement
Under certain circumstances, Verve Global Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Verve Global Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:
• To comply with a legal obligation
• To protect and defend the rights or property of Verve Global Ltd
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Your Data Protection Rights under GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Verve Global Ltd aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data. If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
• The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Verve Global Ltd relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
ActiveCampaign is our CRM service which has a site tracking feature that tracks visits made to our website and associates those page visits with contact records. It also collects the IP address of our contacts when a form is submitted on this site. Site tracking allows us to see which web pages a contact visits so we can create segments and send targeted campaigns and display site messages to specific contacts. You can opt-out of the tracking on the tracking consent notice that is displayed to you the first time you use the service. This has to be accepted or declined to minimise the dialog box.
Google Adwords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
Links to Other Sites
Our Service does not address anyone under the age of 18 ("Children"). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Contact us / How to complain
We endeavor to meet the highest standards when collecting and using personal information, however if you wish to lodge a complaint as to how we collect and process your Information please contact firstname.lastname@example.org. You may also wish to lodge a complaint with the Information Commissioner’s Office, the UK’s independent body set up to uphold information rights. You can find further details as to how to do this at https://ico.org.uk/concerns/