Privacy Policy

PRIVACY NOTICE

INTRODUCTION

On behalf of both Vision RT & the SGRT Community, Vision RT (ICO registration ZA217302) takes your
privacy very seriously. This Privacy Notice is intended to set out your rights and answer any queries
you may have about your personal data. If you need more information, please contact:

PrivacyTeam@visionrt.com

Our personal information handling policy and procedures have been developed in line with the
requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC) and the
General Data Protection Regulation (in force from 25 May 2018) and applicable national law.

NOTICE DETAILS

1. What information do we collect?

We collect and process personal data about you when you interact with us and our products and when
you purchase goods and services from us. The personal data we process includes:

  • Your name;
  • Your home or work address, email address and/or phone number;
  • Information related to the browser or device you use to access our website;
  • And/or any other information you provide

2. How do we use this information and what is the legal basis for this use?

We process the personal data listed in paragraph 1 above for the following purposes:

  • As required to establish and fulfil a contract with you, for example, if you make a purchase
    from us or enter into an agreement to provide or receive services. This may include verifying
    your identity, taking payments, communicating with you, providing customer services and
    arranging the delivery or other provision of products or services. We require this information
    in order to enter into a contract with you and are unable to do so without it;
  • To comply with applicable law and regulation;
  • In accordance with our legitimate interests in protecting Vision RT’s legitimate business
    interests and legal rights, including but not limited to, use in connection with legal claims,
    compliance, regulatory and investigative purposes (including disclosure of such information
    in connection with legal process or litigation);
  • With your express consent to respond to any comments or complaints we may receive from
    you, and/or in accordance with our legitimate interests including to investigate any
    complaints received from you or from others, about our website or our products or services;
  • We may use information you provide to personalise (i) our communications to you; (ii) our
    website; and (iii) products or services for you, in accordance with our legitimate interests;
  • To monitor use of our websites and online services. We may use your information to help us
    check, improve and protect our products, content, services and websites, both online and
    offline, in accordance with our legitimate interests;
  • In circumstances where you contact us by telephone, calls may be recorded for quality,
    training and security purposes, in accordance with our legitimate interest; and
  • We may use your information to invite you to take part in market research or surveys.

We may also send you direct marketing in relation to relevant products and services. Electronic direct
marketing will only be sent where you have given your consent to receive it, or (where this is allowed)
you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic
direct marketing at any time by following the instructions in the relevant communication.

3. With whom and where will we share your personal data?

We may share your personal data with our subsidiaries to process it for the purposes of inter-group
administration and to deliver products or services where elements of these are provided by group
companies other than those with which you have directly contracted.

We may also share your personal data with the below third parties:

  • Our professional advisors such as our auditors and external legal and financial advisors;
  • Agencies where they have agreed to process your personal data in line with this Privacy
    Notice;
  • Our suppliers, business partners and sub-contractors

Personal data may be shared with government authorities and/or law enforcement officials if required
for the purposes above, if mandated by law or if needed for the legal protection of our legitimate
interests in compliance with applicable laws. Personal data may also be shared with third party service
providers who will process it on behalf of Vision RT for the purposes above. Such third parties include,
but are not limited to, providers of website hosting, maintenance, call centre operation and identity
checking.

In the event that our business or any part of it is sold or integrated with another business, your details
will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new
owners of the business.

4. How long will you keep my personal data?

We will not keep your personal information for any purpose for longer than is necessary and will only
retain the personal information that is necessary in relation to the purpose. We are also required to
retain certain information as required by law or for as long as is reasonably necessary to meet
regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and
conditions.

Where you are a customer, we will keep your information for the length of any contractual
relationship you have with us and after that for a period of at least 5 years after final discontinuance
of the production of the model you have purchased.

5. Where is my data stored?

The personal data that we collect from you may be transferred to, and stored outside the European
Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us
or for one of our suppliers, in which case the third country’s data protection laws will have been
approved as adequate by the European Commission or other applicable safeguards are in place.
Further information may be obtained from our Privacy Team.

6. What are my rights in relation to my personal data?

You have the right to ask us not to process your personal data for marketing purposes. You can
exercise your right to prevent such processing by checking certain boxes on the forms we use to collect
your data, clicking the unsubscribe button on any communication we have sent to you or by contacting
us.

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to
correct or supplement it.

You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any
personal data we hold about you.

Where you have provided your data to us and it is processed by automated means, you may be able
to request that we provide it to you in a structured, machine readable format.

If you have a complaint about how we have handled your personal data, you may be able to ask us to
restrict how we use your personal data while your complaint is resolved. In some circumstances you
can ask us to erase your personal data (a) by withdrawing your consent for us to use it; (b) if it is no
longer necessary for us to use your personal data; (c) if you object to the use of your personal data
and we don’t have a good reason to continue to use it; or (d) if we haven’t handled your personal data
in accordance with our obligations.

7. Where can I find more information about Vision RT’s handling of my data?

Should you have any queries regarding this Privacy Notice, about Vision RT’s processing of your
personal data or wish to exercise your rights you can contact Vision RT’s Privacy Team using this email
address: PrivacyTeam@visionrt.com. If you are not happy with
our response, you can contact the Information Commissioner’s Office: https://ico.org.uk/)