Privacy & Cookie

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Privacy Notice

This privacy policy is provided in a layered format, so you can click through the specific areas set out below:

At VoxFP we care about your privacy and we respect your privacy rights in regards to your personal data. We have created this Privacy Notice to demonstrate our firm commitment to your privacy. The following outlines this commitment to users of our website (as defined below) as we want to be able to provide everyone with an experience that is safe and secure. VoxFP endeavours to ensure that any personal data you provide to us via the company website remains private and is used only for the purposes outlined in this Privacy Policy. By using the company Website, you acknowledge the collection and use of your personal data as outlined below. This version of the privacy policy was last updated on 24/05/2018.

1. About Our Privacy Policy

Our website voxfp.com includes any webpage containing this domain name, including any page that is enabled for use by a mobile device or any webpage redirected from another domain name (the “Website”) and the services provided on the Website are operated by Vox Financial Partners Ltd.,
The Scottish Provident Building, 7 Donegall Square West, Belfast, BT1 6JH.
The Website provides information on:

  • who VoxFP are;
  • the services VoxFP provide;
  • company history;
  • company contact information;
  • social media links;
  • company career information 

VoxFP is the data controller and, at times, the data processor (as defined under Data Protection Law) and responsible for the personal data it collects through the Website.
This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and your rights in relation to your personal data. If you are a Customer or Employee, this Privacy Notice supplements any data protection provisions contained in our contract with you and is not intended to override them. Please read the following carefully to understand our views and practices regarding your personal data, how we will treat it and your data protection rights. The Website is not intended for children and we do not knowingly collect personal data relating to children.

2. Personal Data we collect and process

When accessing the Website, we will collect and gather the following categories of personal data:

  • Identity Data such as first name, surname, gender, date of birth.
  • Contact Data such as address, email address, telephone number
  • Employment Data such as previous employers, qualifications
  • Technical Data such as internet protocol (IP address), browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.

The types of personal data collected and used  varies dependent on how you are using the Website, most data collection will take place through our careers section.

3. How we collect Personal Data on the Website

We will inform you at the time of collecting personal data from you whether you must provide the personal data to use the Website or whether the provision of personal data requested by us is optional. We will inform you at the time of collection whether your personal data will be accessible to other users of the Website or third parties, so that you can decide whether to provide it.

It is not necessary to register an account and so is not compulsory to provide any personal data in order to use the website. However, we will receive Technical Data when your browse the website. This is further outlined below.

The only exception is notable when using the careers section of the Website. Basic personal information including name, contact details, address and employment/educational history is required in order to apply/ show interest in advertised roles.

We use Direct Interaction to collect personal data when you use the Website. You may give us Identity, Contact, Address, Employment or Educational data when applying for a vacancy with us or making a contact request.

Additionally, we use Automated Technologies or Interactions to collect personal data. As you interact with the Website, we collect Technical Data and Usage Data, including details of your device, browsing actions and patterns, searches, job advertisements viewed, traffic data, web logs and other communications and resources you access. We collect this personal data by using cookies, server logs and other similar technologies.

4. How we use your Personal Data

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:

  • When we need to perform the contract, we are about to enter into or have entered into with you
  • 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
  • We need to comply with a legal or regulatory obligation
  • We have your express consent. We will not assume consent just because you have not said you do not consent

We generally do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw your consent at any time by contacting us.

We will normally not request from you and we request you do not provide any special categories/sensitive personal data (eg. personal data relating to racial or ethnic origin, political or religious opinion, membership of a trade union, physical or mental health or condition or sexual orientation). This type of data is subject to special protections under current Data Protection Law.

We may process your personal data for one or more lawful basis depending on the specific purpose for which we are using your personal data. Please contact gdpr@voxfp.com if you need details about the specific legal grounds we are relying on to process your personal data.

5. Change of purpose

We will only use your personal data for the purposes under 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 we need to use your personal data for an unrelated purpose, we will notify you and 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 it is required or expected by law.

6. Disclosure of Personal Data to others

Except as set out in this Privacy notice, we will not disclose to any third party personal data that we collect, or you provide to us. We may disclose your personal data to third parties expressly mentioned under our company Data Protection Policy  and the following third parties:

  • Our clients with whom you may be consulting into should you be applying for a vacancy through our careers section.
  • Any member of our groups of companies, which means our subsidiaries, holding company and its subsidiaries, where it is necessary to do so for provision and administration of services
  • We contract with other companies to perform certain tasks on our behalf and who we hold Processor Agreements with. Such service providers include IT systems suppliers and support, data storage, IT developers, website hosting providers and other service providers
  • Legal entities who regulate or have legal jurisdiction over VoxFP. We will disclose your personal data in order to comply with any legal obligation, if we are ordered to do so by a court or competent jurisdiction, law enforcement, regulatory or administrative authorities in order to enforce or apply our agreements, or to protect the rights, property, or safety of VoxFP, our customers or others. This includes exchanging personal data with other third parties for the purposes of fraud protection and credit risk reduction.

We require all third parties to respect the security of your personal data and treat it in accordance with the law. We do not allow our third-party processors 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 as set out in processor contracts we hold with all third parties who process data on our behalf. Unless prevented by applicable law, we will notify you when your personal data may be provided to third parties in ways other than explained above, and you may have the option to prevent such sharing at the time we notify you.

7. International Data Transfers

As VoxFP is a company that operates globally, especially in North America, your personal data may be transferred, stored and accessed from countries outside of the European Economic Area (EEA) in order to fulfil the purposes described in this privacy notice. For transfers to countries outside of the EEA, the data protection regime may be different than in the country in which you are located and will therefore be based on a legally adequate transfer method.

Whenever VoxFP transfers your data out of the EEA, we ensure a similar degree of protection is given to it by ensuring at least one of the following safeguards is in place or implemented:

  • Where the country the data is being transferred to has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • We may use specific contracts approved by the European Commission which gave personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where service providers are based in the US, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

We will provide you on request a list of countries outside of the EEA to which personal data may be transferred and an indication of whether they have been determined by the European Commission to grant adequate protection to personal data. Where applicable, you are entitled, upon request to receive a copy of the relevant safeguard that has been taken to protect personal data during such a transfer.

8. Data Security

VoxFP is committed to protecting the personal data you provide us. To prevent unauthorised access or disclosure of personal data under our control, VoxFP has appropriate security management protocols in place to safeguard the personal data we collect and process. While VoxFP makes reasonable efforts to protect all personal data, no data transmission over the internet is 100% secure. As a result, VoxFP cannot ensure or warrant the security of any personal data you transmit to us, you do so at your own risk. You acknowledge that we are not responsible for any intercepted information sent via the internet, and you hereby waive, release and discharge us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.

9. IP addresses and Cookies

We may collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration and statistical purposes.

For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. On revisiting the website our computer will recognise the cookie, giving us information about your last visit. They help us to improve the website and to deliver a better and more personalised service. They enable us:

  • To estimate our audience size and usage pattern;
  • To store information about your preferences, and so allow us to customise the Website according to your individual interests and make usage of the Website more enjoyable; and
  • To speed up your experience

You may refuse to accept cookies by activating your setting on your browser which allows you to refuse the setting of cookies.

For more information about how to control your cookies go to www.allaboutcookies.org

10. Data Retention

We retain your personal data for no longer than is allowed under data protection law and, in any case, no longer than such personal data is necessary for the purpose for which it was processed. To determine the appropriate retention period for personal data, we consider the amount, nature, sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you respond to a job vacancy or posting by sending your CV/resume to our HR & Recruitment team, a copy of your CV/Resume will remain on our system for no longer than 6 months after the initial job posting has closed. Should you receive any contact in the interim and agree for your application to be stored in the VoxFP Talent Pool, your details will remain on our system for a maximum of 18 months. At the end of the 18 months we will contact you to let you know we are planning to remove your personal data and allow you the opportunity to request we continue to hold the data or to delete it. We will normally remove your CV/resume from our system 6 moths after the job posting has been closed; unless you have stated that you would like your CV/resume stored or have your data stored in the Vox Talent Pool or have exercised your right to erasure before this.

11.Your Legal Rights

Under certain circumstances, you have rights over the processing and use of your personal data under applicable data protection law. Namely:

  • The right to Informed – This allows you to be informed about the collection and use of your personal data. Upon collection of data, you will be provided with information on:
    1. The purposes for processing your personal data;
    2. Retention periods for your personal data;
    3. If and who the data will be shared with
  • The right to Access – This allows you to receive a copy of the personal data we hold about you and allows you to check that they are lawfully process (commonly requested through a “Data Subject Access Request”)
  • The right to Rectification – This allows you to have any personal data that we hold on you to be correct if it is incomplete or inaccurate. We will need to verify the accuracy/ inaccuracy of the data before making any changes first
  • The right to Erasure – This enables you to request that we delete or remove personal data where there is no good reason for us continuing 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 data unlawfully or where we are required to remove your personal data under local law.
  • The right to Restrict Processing – This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    1. If you want us to establish the data’s accuracy;
    2. Where our use of the data is questioned to be unlawful, but you do not want us to erase it;
    3. 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
    4. You have objected to our use of the data, but we need to verify whether we have overriding legitimate grounds to use it.
  • The right to Data Portability – We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used and 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
  • The right to Object – 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.
  • The right to Withdraw Consent – This enables you to withdraw consent for processing your personal data at any time, and to the extent we are relying on consent as the legal basis 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your personal data (or exercise any of your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive and excessive. Alternatively, we ay refuse to comply with a request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask for further information in relation to your request to speed up the response. In this case, processing of your personal data (ie, you contact details) is necessary to facilitate your request.

In order to exercise your rights, please contact gdpr@voxfp.com. We will respond to your request within the legally required period of time. As far as the law allows, if the request is numerous or complex in nature, we may extend the time allocated to complete the request. However, we will inform you of this within the legally required period of time if required.

You have the right to make a complaint at any time to the Information Commissioners Office (https://ico.org.uk/) or any other supervisory authority within your area. We would, however, appreciate the opportunity to deal with your concerns before you approach ICO so please contact us in the first instance on gdpr@voxfp.com.

12. Changes to your Privacy Policy

Any changes we make to our Privacy Policy in the future will be updated on this Privacy Notice and you may also be notified by email. You should visit this page periodically to review any changes to the Privacy Policy.

13. Contact Us

We have an appointed Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about the Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the following details: The Data Protection Officer Vox Financial Partners, Scottish Provident Building, 7 Donegall Square West, Belfast, BT1 6JH Alternatively, you can address your query to the Data Protection Officer through gdpr@voxfp.com.