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Privacy Policy

Last updated: 1 June 2025  ·  Effective: 1 June 2025  ·  Controller: VLS Sourcing Pvt. Ltd.

Contents

  1. Who We Are
  2. Data We Collect
  3. How We Use Your Data
  4. Legal Basis for Processing
  5. International Transfers
  6. Third Parties
  7. Retention Periods
  8. Your Rights
  9. Cookies
  10. Contact & Complaints

Summary: VLS Sourcing UK collects limited personal data from website visitors and business enquiries. We do not sell your data, we do not send unsolicited marketing, and we store your data only as long as necessary. If you have questions, email us at privacy@vlssourcing.uk.

1. Who We Are

Data Controller: VLS Sourcing Pvt. Ltd., New Delhi, India (trading as VLS Sourcing UK at vlssourcing.uk).

UK Representative: As a non-UK-established controller offering services to UK data subjects, VLS Sourcing is subject to UK GDPR (retained in UK law by the Data Protection Act 2018) and designates its founder, Kunwar Vaibhav Singh, as the UK contact point for data protection matters.

Contact for data matters: privacy@vlssourcing.uk

2. Data We Collect

2.1 Data you provide directly

When you complete the enquiry form on our website, we collect:

  • First and last name
  • Business email address
  • Company name and size
  • Telephone number (optional)
  • Details of the roles or services you are enquiring about
  • Any additional information you choose to include in your message

2.2 Data collected automatically

When you visit vlssourcing.uk, our hosting provider may automatically collect standard server log data, including:

  • IP address (anonymised where possible)
  • Browser type and version
  • Operating system
  • Referring URL
  • Pages visited and time of visit

This data is used solely for security and performance monitoring. We do not use it to identify individuals.

2.3 Data we do not collect

We do not collect special category data (health, ethnicity, religion, political opinions, etc.), payment card data, or data from children under 16.

3. How We Use Your Data

We use the personal data you submit to:

  • Respond to your enquiry and provide a cost proposal
  • Arrange and conduct a discovery call if requested
  • Send relevant service information if you have expressly requested it
  • Fulfil any subsequent contractual engagement
  • Comply with our legal obligations

We do not use your data for automated decision-making or profiling.

4. Legal Basis for Processing (UK GDPR Article 6)

We process your personal data on the following legal bases:

  • Legitimate interests (Article 6(1)(f)): Responding to business enquiries you have initiated. Our legitimate interest is to provide information about our services to people who have expressly asked for it.
  • Contract performance (Article 6(1)(b)): Where a service agreement is in place, processing is necessary to fulfil that contract.
  • Legal obligation (Article 6(1)(c)): Where required by law (e.g., financial record-keeping).

We do not rely on consent as our primary basis for processing enquiry data, as UK GDPR provides a more appropriate basis (legitimate interests) for business-to-business communications where you have actively contacted us.

5. International Data Transfers

VLS Sourcing Pvt. Ltd. is based in India. When you submit an enquiry via our website, your personal data is transferred to and stored in India.

The UK Government has not issued an adequacy decision for India. We therefore rely on Standard Contractual Clauses (SCCs) as the transfer mechanism for any personal data transferred from UK data subjects to our Indian entity, supplemented by a Transfer Impact Assessment where appropriate.

If you are a business client engaging us under a service agreement, we will provide a Data Processing Agreement (DPA) covering the transfer and processing of any personal data your organisation shares with us.

6. Third Parties

We do not sell, rent, or trade your personal data to any third party for marketing purposes.

We may share data with the following categories of processor, under appropriate data processing agreements:

  • Email and communication tools (e.g., Google Workspace) — for receiving and responding to enquiries
  • Website hosting provider — for serving the website and storing server logs
  • Video conferencing tools (e.g., Google Meet, Zoom) — where you book a call with us

Each third-party processor is required to process data only on our instructions and in accordance with applicable data protection law.

7. Retention Periods

  • Enquiries that do not result in a contract: We retain enquiry data for a maximum of 12 months, after which it is securely deleted.
  • Contracts and invoices: Retained for 7 years in accordance with UK financial record-keeping requirements.
  • Server logs: Retained for a maximum of 90 days for security purposes.

8. Your Rights Under UK GDPR

As a UK data subject, you have the following rights:

  • Right of access: To request a copy of the personal data we hold about you.
  • Right to rectification: To request correction of inaccurate data.
  • Right to erasure ("right to be forgotten"): To request deletion of your data, subject to legal retention obligations.
  • Right to restrict processing: To request that we limit how we use your data in certain circumstances.
  • Right to data portability: To receive your data in a commonly used, machine-readable format.
  • Right to object: To object to processing based on legitimate interests.
  • Rights related to automated decision-making: We do not carry out automated decision-making.

To exercise any of these rights, email privacy@vlssourcing.uk. We will respond within one calendar month. We may need to verify your identity before processing your request.

9. Cookies

Our website currently uses only essential cookies necessary for the website to function (e.g., session management). We do not use analytics cookies, advertising cookies, or third-party tracking cookies without your consent.

If we introduce non-essential cookies in future, we will update this policy and implement a cookie consent mechanism. You can control cookies through your browser settings at any time.

10. Contact & Complaints

To contact us about this policy or to exercise your rights:
Email: privacy@vlssourcing.uk
Subject line: "Data Protection Enquiry"

We aim to respond to all data protection queries within one calendar month.

Right to complain to the ICO: If you are not satisfied with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection:

  • Website: ico.org.uk
  • Telephone: 0303 123 1113

We would appreciate the opportunity to address your concerns before you contact the ICO, so please reach out to us first.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law or our practices. We will update the "last updated" date at the top of this page. For material changes, we will take reasonable steps to notify existing clients directly.

This Privacy Policy is governed by the laws of England and Wales. Return to homepage →

VLS Sourcing United Kingdom

Remote staffing and Employer of Record services for UK businesses. GDPR-compliant, IR35-safe, fully managed. Est. 2014.

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