This Policy together with any other documents referred to on it sets out the basis of:
- What Personal Data we collect and why
- What we do with your Personal Data
- How we secure your Personal Data
- How you can change or delete your Personal Data
Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
‘We’, ‘Us’ or ‘Our’ - Refers to Create Internet Ltd (trading as Viva!)
‘Site’ - means the public area of viva.website
‘User’, ‘You’ or ‘Your’ - means a person who uses our Site or has registered to use our Services
‘Registration Process’ - the online actions required in order to become a User
‘Account’ - means any area of viva.website that you manage which requires you to log in using your designated login details
‘Subscription’ - refers to any paid services or features that Viva! offers that requires an online payment by a user
‘Personal Data’ - means any information that can personally identify an individual
‘End Users’ - the users and the visitors of your website created through Viva!
‘Data Protection Laws’ - refers to all laws and regulations, including laws and binding regulations of the UK (including the UK Data Protection Act 2018) and European Union (including the General Data Protection Regulation & the e-Privacy Directive 2002/58/EC)
What Information We Collect
The legal basis in which we process information we collect is in order for us to provide the Service outlined in our Terms and is in our legitimate interests which are further explained in ‘How We Use The Information Collected’ section of this Policy.
We may collect and process various forms of information when you use our Site or Services:
‘User-Provided’ Information - When you use our Site or Service, you may provide Personal Data and we as a result, may collect this. Personal Data is any form of information that can identify an individual for example, name, email address, mailing address, and credit card or other billing information. Examples of when this information may be provided include, but are not limited to, when you register to our Site, enter a Subscription and when you have contacted us.
‘Automatically Collected’ Information - If you use our Site or Service we may automatically collect information about your computer, including your IP address (where available), operating system and browser type. We achieve this by using cookies and other forms of technology. All of the information that is automatically collected is statistical data about our Users browsing actions and patterns. Some of this information is stored for security purposes so we can alert you of any suspicious activity on your account.
‘User Collected’ Information - We may collect Personal Data to ensure full functionality of the features provided depending on how you, the User, use our Service. For example, we may store names, mailing addresses and contact numbers (amongst other information) of your customers through our mail provider in order for you to receive any enquiries through your website. For this purpose, Viva! is the data processor. Each User is responsible for providing notice to their customers or users detailing what Personal Data may be processed through our Service, and the reasons for doing so.
‘Third-Party’ Information - Single Sign-On (SSO) software is used as part of the registration process to our Service. SSO is provided through Google and Facebook and these third-parties will grant us access to certain Personal Data in order for us to verify your identity during the registration process. The Personal Data that we have access to includes your name, email and profile picture (if applicable).
How We Use The Information Collected
We use the information that we collect in a variety of ways during the provision of our services and operation of our business, including the following:
- To ensure that all the features we provide are available, functional and maintained as per the specifications advertised
- To carry out our obligations arising from any contracts entered between you and us
- To carry out any business essential administrative processes
- To allow you to participate in interactive features of our Service, when you choose to do so
- To enhance the Service we provide by developing new features, and improving the functionality of existing features
- To enable our team to provide support to Users when requested or required to do so
- Investigate any issues that arise from using our Service
- To notify you of any changes to our Service
- To provide any information you have requested or that we feel may be of genuine interest to you. These include updates about the services we offer, promotions and general business information which may or may not be connected to third parties we work with. You have the right to opt-out of receiving any promotional information as detailed below under ‘Your Rights’ of this Policy.
We use the following cookies:
Strictly Necessary cookies - These are essential in order to enable you to move around our Site and use its features, such as accessing secure areas of the Site. Without these cookies, certain services or features advertised cannot be provided.
Performance cookies - These allow us to recognise and count the number of visitors and to see how visitors move around our Site . These cookies also enable Us to monitor the performance of your Site (page loading speeds, etc) to ensure that everything is functioning correctly. This also helps us to improve the way our Site works, for example, by ensuring that Users are finding what they are looking for easily. The information collected by Performance Cookies is aggregated and can’t be used to personally identify any individual.
Functionality cookies - These allow the Site to remember choices you make and provide enhanced, more personal features. For example, greet you by name and remember your preferences within the application. These cookies can also be used to remember changes you have made to text size, fonts and other parts of our Service that you can customise. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
You can find out more information about cookies and how to disable them by visiting https://cookiesandyou.com.
We use Google Analytics (which includes Google Tag Manager) to measure traffic to our Site and understand how Users move around and use our Service. This information is collected using cookies provided by Google Analytics. We use the information collected to enhance the Site and Service we provide to ensure that Users get the best experience possible. We also use Google Analytics to monitor aggregate information of your website which helps us monitor the performance of features we offer within our Service to ensure full functionality. The information gathered also enables us to improve these features in the future. All of the information we collect from Google Analytics is aggregate and will not be disclosed to any other third-parties.
How We Store The Information We Collect
When your information is submitted to us, we use it to ensure that appropriate security measures are in place to ensure your information is protected. These safeguards are implemented to ensure that Personal Data in our possession is not subject to any unlawful forms of processing which include accidental loss, unauthorised access or disclosure. Our Site and Services have Secure Socket Layer (SSL) encryption present amongst other general security measures such as firewalls and password protection to certain areas of our Service. Our employees are trained to ensure that all administrative processes are followed to ensure that your data is handled and processed in line with Data Protection Laws. These measures are regularly reviewed to ensure that your Personal Data is being stored in the most secure way possible.
The data we collect from you may be processed, transferred and stored using various services integral to our business operations. These services may be based in locations outside of the European Economic Area (EEA), primarily the United States, and only the essential and necessary data will be provided to them for them to fulfill their purpose. Data may also be processed by a member of staff operating outside the EEA who is employed by us. Such staff may be engaged in, amongst other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your Personal Data to us, you agree to the transfer, storing and/or processing of your Personal Data .
We have ensured that all services we use to transfer, store and/or process data, in or outside the EEA, have been verified to ensure that they are compliant with Data Protection Laws and any other respective legal framework that applies to that particular service for example, the EU-US Privacy Shield.
Further to this, we will continually monitor said services to ensure compliance is still being achieved at any given time and the data they hold is stored in a safe and satisfactory manner using the most up to date security measures. We will, to the best of our knowledge, not process, store or transfer any data to any service that does not comply with Data Protection Laws or have adequate security measures in place to protect your Personal Data .
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 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.
Disclosure of Information
We will only disclose your information to any third-parties as detailed in this Policy and under the following circumstances:
- In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets.
- If Create Internet Ltd or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets.
- To our domain name registries, in order to register domains on your behalf.
- To facilitate payment (for example, Stripe).
- If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce our Terms and other agreements; or to protect the rights, property, or safety of Create Internet Ltd, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- In order for them to provide you with information about goods and services which may be of interest to you.
- If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you can do so by emailing us through our contact form. For more information, please see the ‘Your Rights’ section of this Policy.
We do not disclose any personally-identifiable information about individuals to our advertisers, but we may provide them with aggregate information about our Users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisements on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, men in the BN1 postal area). We may make use of the Personal Data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
Protecting the privacy of children is particularly important in data protection. As stated in our Terms, anyone under the age of 18 is not eligible to use our Service. We do not knowingly collect any Personal Data of anyone younger than 18.
If we become aware of any Personal Data that has been gathered on a child who is under the age of 18, we will take the appropriate action to ensure it is removed from our system.
If you, as a parent or guardian, discover that your child (under the age of 18) is using our Service, please notify us through our contact form and will we take the relevant action to ensure the Personal Data of the child is erased.
Access To Information & Your Rights
We are committed to protecting and respecting your privacy within your account. Under Data Protection Laws, as a User of our Service, you have several rights in relation to your Personal Data which include:
The right of access - you have the right to know exactly what information we hold about you and how we process it.
The right of rectification - you have the right to have your Personal Data rectified if it is incorrect or incomplete.
The right to be forgotten - you have the right to have your Personal Data removed or deleted without a specific reason for doing so. This is also known as ‘the right to erasure’.
The right to restrict processing - an individual's right to block or suppress processing of their Personal Data . You have the right to block your Personal Data from being processed.
The right to data portability - you have the right to request the Personal Data we hold about you for your own use.
As a User, you can access, change and delete certains types of data that we hold about you within your account. For more information on what personal information you can access in your account, please contact us. If you wish to exercise any of your rights in accordance with Data Protection Laws, please contact us with the specific request using the contact details located under the ‘Contact Us’ section of this Policy. The action taken will be free of charge, provided in an easily accessible format (if applicable) and actioned within 30 days, where possible.
If you have concerns about the way we handle your Personal Data , you can contact the ICO or raise a complaint by contacting us and we will investigate accordingly.
We will continue to retain any information collected from a User of our Service as long as the Users account is deemed active. An account is deemed active unless a specific request from a User has been emailed through our contact form stating that they would like to ‘deactivate’ their account or a similar requests to permanently remove Personal Data.
We may still hold personal information of inactive accounts under the following conditions:
- If required to do so in order for us to continue our duties as a domain registrar or other domain hosting services
- If required for financial records in line with UK accounting and taxation laws (for a period of at least 6 years, plus the current year)
- If deemed necessary due to any legal obligations or regulatory investigations that may arise
You can contact us at any time if you have any questions, comments or requests regarding this Policy using the following information:
Create Internet Ltd (Viva!), Unit 5, Westergate Business Centre, Westergate Road, Brighton, East Sussex, BN2 4QN.
Email us through the Contact Us page on our Site.
Changes To This Policy
Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you by email.