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Privacy Policy

SME HCI Limited, trading as Vivup (“Vivup”), respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you

1. Important information and who we are 

Purpose of this privacy policy 

This privacy policy aims to give you information on how Vivup collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up for information from us about our services. 

This website is not intended for children, and we do not knowingly collect data relating to children. 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 


Data Controller 

SME HCI Limited trading as Vivup is the controller and is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy). We will also oversee questions in relation to this privacy policy. 

Such personal data is processed by Vivup as a data controller. This includes the following instances: 

  1. Webinars or workshops; 
  2. verifying the Employer as a suitable IAR (and any individual as an Approved Person) and for procuring compliance with the FCA Regulations and the IAR Agreement, such personal data is processed by Vivup as a Data Controller; 
  3. for Vivup’s internal business management and financial purposes, such personal data is processed by Vivup as a Data Controller;   
  4. Transactions via Vivup Products and Services such as Orders for equipment or appliances and/or bicycles under the Cycle to Work Scheme (where acting as the lessor/supplier). 


Contact details 

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways: 

Email address: 

Postal address:  PO Box 736, Farnham, GU9 1DQ 

You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact Vivup, who will respond on our behalf, in the first instance. 


Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review. 

This version was last updated on 06/12/2023

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 


Third-party links 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. 

Vivup collaborates with Eventbrite, event management and ticketing service, to facilitate our webinars. Eventbrite acts as a processor, assisting Vivup in the administration for our webinar events. Vivup collects personal data through registration forms on our webinar page, which is then transferred to Eventbrite for webinar event administration. We ensure that the processing of your personal data complies with the principles of the UK/EU General Data Protection Regulation (GDPR).   

A link to Eventbrite’s privacy policy can be found here: Eventbrite Privacy Policy | Eventbrite Help Centre 


2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (“anonymous data”). 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows: 

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, Employee Number, NI Number and gender. 
  • Contact Data includes address, email address and telephone numbers.  
  • Salary Information includes salary bracket, benefit amount, and annual salary.  
  • Transaction Data includes details about products and services you have ordered in connection with the Benefit. Information about specific items ordered is not visible to us. 
  • Technical Data includes internet protocol (“IP”) address, your login data, 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 this website [ (the “Site”)]. 
  • Profile Data includes orders made by you, your interests, preferences, feedback and survey responses. 
  • Usage Data includes information about how you use the Site, products and services. 
  • Communications Data includes your communication preferences. 


We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.


We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.


If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time. 


3. Personal data collected from you in relation to the Vivup Platform

We use different methods to collect data from and about you including through: 

  • Direct interactions. You may give us your Identity, and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 
  • request information about our services be sent to you; 
  • enter a competition, promotion or survey; or 
  • give us feedback or contact us; 
  • register for our webinars; 
  • make an order for products or services; 
  • create an account; 
  • subscribe to publications. 

  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third parties or publicly available sources. Not all the personal information we hold about you will always come directly from you. We may also collect information from third parties such as our partners, service providers and publicly available websites (i.e., social media platforms), to comply with our legal and regulatory obligations, offer services we think may be of interest, to help us maintain data accuracy and provide and enhance the Services. For example, we may receive Identity, Contact and Technical Data if you log into one of our products through Facebook, Facebook provides us with some of your Facebook user details. We may use these details for the purposes of our registration process and to market our products and services to you on Facebook. We may also obtain Technical Data from analytics providers such as Google.


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: 

  • 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. Furthermore, where it is necessary for our legitimate interests to enrol you in the Vivup Platform to provide our staff benefits package and your interests and fundamental rights do not override those interests. 
  • Where we need to perform the contract we are about to enter into or have entered into with you 
  • Where we need to comply with a legal obligation. 

Below are further details of the types of lawful basis that we will rely on to process your personal data: 

Legitimate Interest means the interest of our organisation in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This also means the services we are providing to you through your Contract of Employment/Terms of Service. 

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. 


Purposes for which we will use your personal data 

We have set out below, in a table format, a description of all the ways we plan to use your personal data.



Type of data 

Lawful basis for processing including basis of legitimate interest 

To process and deliver your order including: 

  • Manage payments, fees and charges such as payroll deductions 
  • Collect and recover money owed to us 
  • For compliance with a legal obligation that we are subject to 

(a) Identity 

(b) Contact 

(c) Salary Information 

(d) Transaction 

(e) Communications 

Performance of a contract with you 

Necessary to comply with a legal obligation 


To manage our relationship with you which will include: 

Notifying you about changes to our terms or privacy policy 

(a) Identity 

(b) Contact 

(c) Profile 

(d) Marketing and Communications 

Performance of a contract with you 

Necessary to comply with a legal obligation 


To enable you to leave a review, partake in a prize draw, competition, or complete a survey 

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Marketing and Communications 

Legitimate interests (to keep our records updated and to study how you use products/services to develop and make more relevant to you) 



To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(a) Identity 

(b) Contact 

(c) Technical 

Necessary to comply with a legal obligation. 


Legitimate interests (for running our business and the provision of administrative and IT services) 


To deliver relevant website content to you and measure or understand the effectiveness of the communications 

(a) Identity 

(b) Contact 

(c) Profile 

(d) Usage 

(e) Communications 

(f) Technical 

Legitimate interests (to keep our records updated and to study how you use products/services to develop and make more relevant to you) 


To use data analytics to improve our website, products/services, marketing, customer relationships and experiences 

(a) Technical 

(b) Usage 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to 

 inform our marketing strategy) 

To make relevant suggestions and recommendations to you about goods or services that may be of interest to you 

(a) Identity 

(b) Contact 

(c) Technical 

(d) Usage 

(e) Profile 

(f) Marketing and Communications 

Legitimate interests (to keep our records updated and to study how you use products/services to develop and make more relevant to you) 


To administer signup to Webinars  

(a) Identity 

(b) Contact 


Consent provided by participants during webinar registration.  

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.  

You will receive communications from us and/or Vivup if you have registered or you make an order for any goods or services in connection with a Benefit from us and/or Vivup and you have not opted out/unsubscribed of/from receiving such communications. 


Third-party communications 

You will not receive any communications from a third party unless this is part of the fulfilment process relating to a specific order you have made or if you have given your express opt-in consent directly to that third party to receive communications. As the provider of the platform, any communication sent by Vivup directly or on behalf of your employer are not treated as Third Party communications.  


Opting out or unsubscribing from communications 

You can ask us to stop sending you communications at any time by contacting us or clicking the unsubscribe link in a message. 

Unsubscribing from communications will not apply to messages sent as a result of the fulfilment of an order or when we are required to notify you regarding other important developments or changes. 



You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see 


Change of purpose 

We will only use your personal data for the purposes for 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we 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 this is required or permitted by law. 


5. Disclosures of your personal data 

We may share your personal data with the parties set out below for the purposes set out in the table in Section 4 above. 


  • Internal Third Parties related to your Employer acting as joint controllers or processors. 
  • External Third Parties such as: 
  • Service and other benefits providers acting as data controllers or processors and their suppliers. 
  • Professional advisers acting as processors or joint controllers including lawyers, tax advisors and auditors. 
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances. 
  • Other parties to whom we may choose to sell, transfer or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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. 


6. International transfers

The Vivup Platform is held in UK data centresHowever, we may transfer personal data to a third party that processes data outside the UK or European Economic Area (EEA)To ensure that personal data receives the same protections as if it were being processed in the UK, we require that third parties comply with Data Protection Legislation; including the Standard Contractual Clauses and/or the International Data Transfer Agreement and International Data Addendum (as applicable). A schedule of our suppliers is provided here. 


7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 


8. Data retention

How long will you use my personal data for? 

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. 

The data retention table can be found here. 

In some circumstances you can ask us to delete your data: see your legal rights below for further information. 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 


9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

You have the right to: 

  1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. 
  2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 
  3. Request erasure of your personal data. This enables you to ask us to 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 information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
  4. Object to processing of your personal data 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
  5. Request restriction of processing of your personal data. 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 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. 
    4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 
  6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, 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. 
  7. Withdraw consent at any time where we are relying on consent 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent. 

If you wish to exercise any of the rights set out above, please contact us. 


No fee usually required 

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. Alternatively, we could refuse to comply with your request in these circumstances. 


What we may need from you 

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 you for further information in relation to your request to speed up our response. 


Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it could 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 and keep you updated. 

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