Application of policy
Together with the General Terms of Service, this privacy note applies to the following:
- the Viola Black website found at https://www.violablack.com/;
- Viola Black Mobile App (“App”) which is available once downloaded onto a mobile or tablet device;
- the services offered through Viola Black’s website and App, namely the pre-paid card and account facilities
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.ViolaBlack.com.
Who We Are
Viola Black is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Why Does Privacy Matter To Us?
We are committed to protecting and respecting your privacy! We never sell your data and always keep it safe and private. Transparency and clarity are very important principles for us. If you have any queries concerning your personal information please do not hesitate to contact us through our communication forum – https://www.violablack.com/contact/, or simply email us at firstname.lastname@example.org.
By providing us with your data, you warrant to us that you are over 13 years of age.
If you are unhappy with any aspect of how we collect and use your data, you can contact us directly and we will try our upmost to deal with your concerns. You also have the right to complain to the Information Commissioner’s Office (ICO), who is the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate it however if you raise your issue with us first so that we might deal with it at first instance.
- Email address: email@example.com
- Postal address: 3 Waterton Park, Bridgend CF31 3PH Wales
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at firstname.lastname@example.org.
Information We Collect On You
Submitted Information: When you register with Viola Black, whether through our App or Website, you submit certain personal information. This includes: your name, address, email address, phone number and ID verification number (i.e. passport number, driving licence).
Communication Data : We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
Legitimate reason: We maintain records of any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
Technical Data from Devices: This includes data about your use of our app, website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse use of our website and other online services, to administer and protect our business and website, to deliver relevant website content. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and to develop/grow our business and to decide our marketing strategy.
Data retrieved from using our App, Website and other services: Data is collected from clickstream (mouse activity), this includes time, information viewed or searched for, page response times, interactive information and browser information.
Transactional information: Data is collected in relation to how you spend your money, the time date, location and area where the transaction was entered into, the currency used, beneficiary details, receivers name and registration information, whether you used viola black’s app or online site, beneficiary information IP address of receiver and merchant information such as location and business name.
Sensitive Data: We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time. We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at email@example.com
In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing. We may process your personal data without your knowledge or consent where this is required or permitted by law. We carry out automated decision making as part of the on-boarding procedure. This automated decision-making forms part of the review that is carried out against the information submitted by you to ensure that stated security requirements have been achieved. Should any query be raised in the course of this process you will either be contacted to provide additional information/clarification or to be informed that Viola Black is unable to provide the service that has been applied for.
We will not use Children’s personal data for an unrelated new purpose and will not seek consent to do so.
Information We Receive From Third Parties
We are also working closely with third parties and may receive information about you from them. We are provided with the following details:
- Information from a fraud prevention agencies(s) which indicates your eligibility to use our products
- the banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;
How We Use Your Information
We use your information in the following ways:
- to check that you meet the criteria to receive the product or service we’re offering
- to verify your identity and prevent instances of fraud. This is so we know who our customers are and to make it more difficult for criminals to use false or impersonated identities for criminal purposes, such as hiding the proceeds of crime or committing fraud.
- to provide you with updated policy information concerning your usage of our Services
- to administer our Site and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your computer;
Information We Share With Third Parties
We disclose the personal data you submit to certain third parties who utilise this data so they might perform their contractual obligations to us. We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
The third party with whom we share your data with is dependent on the service we provide to you specifically. If you would like to know which third parties we share your information with then please contact us at: firstname.lastname@example.org.
The following third parties receive your personal data so that Viola can perform its services to you:
- Fraud prevention agencies- We provide this party with your data to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and services.
- Government bodies that require us to report processing activities.
- Other companies in our group who provide services to us. Which can be found here
- Cloud storage providers- This is in order to safely and securely store your data with Viola;
- Banking and financial services partners
- Card manufacturing/personalisation and delivery companies
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case, you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
We will not send Children marketing communications and will not seek consent to do so.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
We will not share Children’s personal data for marketing purposes and will not seek consent to do so.
You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by emailing us at email@example.com. at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations and the like.
Sharing Data Outside Of The EEA
We share your personal data within our group of companies and with third party service providers who may be based outside the European Economic Area (EEA) which, in some instances, involves transferring your data outside the European Economic Area (EEA).
Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.
Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is in place:
- We will only transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
- Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
- If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Data Security- How We Store Your Data
The information which you provide is stored within our secure servers. When you carry out a transaction with a third-party this is information is encrypted using Secured Sockets Layer technology or a secure virtual private network. You are responsible for the safekeeping of your password, whether this is issued by us or chosen by yourself in order to use Viola’s services.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our App or our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We continuously educate and train our employees about the importance of confidentiality and privacy of customer information.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
As an FCA regulated institution, Viola is legally required to store some of your personal and transactional data. Whilst using Viola services we will retain your information and following termination of your account, six years after that. Rest assured, only a small number of our employees can see this data and We always delete information that is no longer in needed.
Your Legal Rights
Under Data protection laws you have rights in relation to your personal data. If you desire to exercise one or more of the below rights please contact us by email at firstname.lastname@example.org.
- Access your personal information: you can make a request to find out what personal data we hold on you and how it is used.
- Correction request (known as the “Right to Rectification”). This means you can request Viola to have inaccurate personal data rectified, or completed if it is incomplete.
- Erasure request: This right, also known as the “right to be forgotten” allows you to ask us to delete your personal data. However, please note that we may not be able to comply with this request as the national law may prohibit us from doing so. In order to comply with anti-money laundering laws we are required to maintain your information for a period of time. These retention requirements supersede any right to erasure requests under the data protection laws.
- Processing objection: The data protection law gives you the right to object to the processing of your personal data. Further, you can object to your data being uses for direct marketing.
- Restriction of processing request: This right allows you to request the restriction or suspension of your personal data. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have entered into with you. In this instance, we may have to cancel your use of Viola Black and it’s services.
Additional Information Request
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
You can see more about these rights at:
Childrens Rights Under GDPR
If your Child utilises the services of the ViolaBlack family, you can find more information about the rights applicable to them:
If you wish to exercise any of the rights set out above, please email us at email@example.com. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.