Privacy Policy

Purpose of This Policy

This document declares the undertakings by Veteran’s Support Group in relation to its handling of Your Data.

Data Collection

Veteran’s Support Group undertakes to collect Your Data by means that are:

• fair
• legal, and
• transparent.

If you visit Veteran’s Support Group’s web-site, your web-browser automatically discloses, and Veteran’s Support Group’s web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you. Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you. Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in ‘cookies’ and submits them each time you request a web-page within a particular domain (such as Veteran’s Support Group.com). This data may or may not be sufficient to identify you. If you disclose personal data to Veteran’s Support Group in conjunction with an identifier such as your name or your credit-card details, Veteran’s Support Group will collect Your Data. Moreover, any data that becomes available to Veteran’s Support Group through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data. Subject to the qualifications immediately below, Veteran’s Support Group undertakes to collect Your Data from you and not from other parties. This undertaking is qualified as follows:

• where Veteran’s Support Group reasonably considers that the protection of its financial interests requires that it gather YourData from other sources, or from additional sources. This applies in particular where Veteran’s Support Group has a lending exposure to you, and seeks information about your creditworthiness
• where Veteran’s Support Group reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering YourData from other sources. This applies in particular to consumer profile data.
• Where Veteran’s Support Group collects Your Data from sources other than you, it undertakes:
  • to do so only by legal means
  • to do so only with your Consent, and
  • to declare to you what sources it uses, and under what circumstances.

Veteran’s Support Group undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as ‘to support our operations’.

Data Security

Veteran’s Support Group undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity. Veteran’s Support Group undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines. Veteran’s Support Group undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity. Veteran’s Support Group undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by Veteran’s Support Group’s staff-members and contractors. These include:

• training for staff in relation to privacy
• access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it, particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data
• reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour
• declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
• clear communication of policies and sanctions, and
• processes to audit, to investigate and to impose sanctions.

Data Use

Use refers to the application of Your Data by any part of Veteran’s Support Group, or any staff-member or contractor of Veteran’s Support Group in the course of their work. Veteran’s Support Group undertakes to use Your Data only for:

• the purposes for which it was collected
• such other purposes as are subsequently agreed between Veteran’s Support Group and You
• such additional purposes as may be required by law. In these circumstances, Veteran’s Support Group will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law, and
• such additional purposes as are authorised by law (in particular to protect Veteran’s Support Group’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Veteran’s Support Group or have committed a breach of the criminal law).
• Veteran’s Support Group undertakes to use YourData only if it has demonstrable relevance to the particular use to which it is being put. Veteran’s Support Group undertakes to use YourData in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.

Data Disclosure

Disclosure refers to making YourData available to any party other than Veteran’s Support Group and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving. Veteran’s Support Group undertakes to disclose Your Data only under the following circumstances:

• in the course of business being conducted between You and Veteran’s Support Group, where disclosure is necessary to a contractor, such as a transport company. Where Your Data is disclosed in this way, Veteran’s Support Group undertakes to exercise control over Veteran’s Support Group’s contractors to ensure that their actions are compliant with these Terms
• in other circumstances that are directly implied by the purpose agreed between You and Veteran’s Support Group at the time of data collection or subsequently. Where Your Data is disclosed in this way, Veteran’s Support Group undertakes to exercise control over Veteran’s Support Group’s contractors to ensure that their actions are compliant with these Terms
• with your consent, or at your request
• where required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena. In these circumstances, Veteran’s Support Group will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law
• where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where Veteran’s Support Group believes on reasonable grounds that the disclosure of YourData will materially assist in the protection of the life of health of some person), provided that Veteran’s Support Group will apply due diligence to ensure that the exercise of the permission is justifiable.

In all cases, Veteran’s Support Group undertakes to disclose only such of Your Data as is necessary in the particular circumstances. Data Retention and Destruction Subject to the qualifications immediately below, Veteran’s Support Group undertakes:

to retain Your Data only as long as is consistent with its purpose, and to destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered.

This undertaking is qualified as follows:

• Your Data may be retained in Veteran’s Support Group’s logs, backups and audit trails within short-term retention cycles that are devised to protect the company’s operations. In such cases, Your Data will be destroyed in accordance with those cycles.
• Your Data may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or sub poena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, Veteran’s Support Group:
  • will take any reasonable steps available to it to communicate to You that Your Data is being retained, unless it is precluded from doing so by law, and
  • will only retain Your Data while that provision is current, and will then destroy Your Data

Your Data may be retained beyond the expiry of its purpose if it is authorised by law (in particular to protect Veteran’s Support Group’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Veteran’s Support Group or have committed a breach of the criminal law). In these circumstances, Veteran’s Support Group will only retain Your Data while that situation is current, and will then destroy Your Data.