Privacy policy

Effective date: 23 October 2025
Version: 1.2

1. Introduction

This Privacy Policy explains how Virtually There Offices Limited (“VT”, “we”, “our” or “us”) collects, uses, stores, and protects personal data in connection with our website, portal, and services.

VT is committed to protecting your privacy and ensuring that your information is handled lawfully, fairly, and transparently in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Our website and the services we provide are not intended for children and we do not knowingly collect data relating to children.

2. Data Controller and Processor Roles

Virtually There Offices Limited acts in a dual capacity:

• As a Data Controller – for user verification, account management, billing, website analytics, marketing communications, and system administration. This Privacy Policy applies to personal data that we handle as a Data Controller.
• As a Data Processor – when handling mail  or other client information on behalf of Users. Further details regarding our role as a Data Processor are set out in our Terms of Service.

3. Our Details

Controller: Virtually There Offices Limited
Registered office: 2.1a Temple Studios, Temple Gate, Bristol, BS1 6QA
Email: data@virtuallythereoffices.co.uk
ICO registration no.: ZA375990

4. Personal Data We Collect

Personal data means any information about an individual from which that person can be identified.

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

• Account & Contact Information: name, email, phone number, billing address, business details and portal login details.
• AML and Verification Data: identification documents, proof of address, beneficial ownership information, and verification results.
• Mail and Portal Data: personal data contained within correspondence received and scanned as part of our virtual-office services.
• Payment Information: subscription details and payment records processed via Chargebee and Stripe.
• Website & Usage Data: IP address, browser type, device information, portal log-ins, and usage patterns via PostHog Analytics.
• Marketing Preferences: opt-ins for news, service updates, or training communications.

We may also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website or portal feature in order to analyse general trends in how users are interacting with our services to help improve our service offering

5. How We Collect Data

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

• Directly from you when you register, subscribe, or contact us.
• Automatically through our website and portal via cookies and analytics tools.
• From third-party identity verification providers (e.g. Sumsub) for AML compliance.
• From public sources where lawfully required (e.g. Companies House filings).

6. How We Use Your Personal Data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) 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).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

7. Marketing Communincations

We may send service updates or compliance notifications as part of your contract. Marketing or promotional emails will only be sent where you have opted in or a legitimate interest exists. 

You may withdraw consent or opt out at any time by following unsubscribe links or contacting us directly. If you opt out of receiving marketing or promotional emails, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to updates to our Terms and Conditions.

We may use limited business information (such as company name, industry sector, and service usage patterns) to offer relevant products, service improvements, or partner integrations that form part of the Virtually There offering.

Where we collaborate with trusted partners to provide complementary products or services, we only share the minimum information necessary and ensure all partners are bound by written confidentiality and data-protection agreements.

Such activity is carried out under our legitimate business interests to improve our services and support clients’ operational needs.

 You may opt out of receiving partner or promotional communications at any time by contacting us or using the unsubscribe link provided.

8. Disclosures of Your Personal Data

From time to time, VT engages independent consultants and third-party service providers to support operations and compliance. Only the minimum information necessary is shared, and each party is bound by a written Non-Disclosure Agreement or equivalent contractual confidentiality terms. 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.
All consultants and providers must implement appropriate technical and organisational measures consistent with UK GDPR.

Regulatory and Legal Disclosures

We may disclose or share personal data where required by law, to enforce our terms, or to protect our rights, property, or safety.

We never sell personal data for marketing or commercial exploitation.

In the event of a merger, acquisition, or sale of the business, personal data may be transferred to the acquiring entity as part of that transaction. In such cases, data will continue to be used only for the same purposes originally collected, under equivalent or stronger data-protection safeguards.

AML Compliance and Retention

VT is registered with HMRC for AML supervision. We are required to retain customer-due-diligence (CDD) records for five years after a business relationship ends (or up to ten years where required by law). AML data may be disclosed to HMRC or law enforcement authorities where legally obliged.

All records are stored securely, access-restricted, and permanently deleted after the maximum retention period.

Certain legal obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (“MLR 2017”) take precedence over standard data-protection rights and retention limits.

Where a legal duty to collect, verify, retain or disclose personal data arises under the MLR 2017 or other applicable law, VT must comply with that duty, even where it may otherwise limit individual rights under data-protection legislation.

This includes, but is not limited to:

• Customer Due Diligence (CDD) and verification records (ID, POA, beneficial-ownership);
• Mail-handling and postal audit data (including logs, sender information and scans) retained as evidence of compliance;
• AML screening results, transaction notes and any information relevant to suspicion reporting or regulatory review.

Requests for deletion, restriction or erasure of such records cannot be fulfilled while VT is under a legal obligation to retain them.

However, to ensure fairness and compliance with UK GDPR, access to such retained data is strictly limited to authorised personnel only, and the data is held in secure, access-controlled archives solely for the purpose of satisfying statutory retention requirements. Once the applicable retention period expires, the data will be permanently deleted or anonymised, which will occur no later than ten years after the end of the business relationship, unless a longer period is required by law, regulation, or an ongoing investigation.

These AML-specific obligations supersede conflicting provisions of the UK GDPR to the extent necessary for VT to meet its statutory compliance and record-keeping duties.

Our Sub-Processors

We use trusted third-party providers to deliver our services. Each is bound by a written data-processing agreement and is assessed for GDPR compliance.

9. International Transfers

Where personal data is transferred outside the UK, VT ensures adequate protection is afforded to it by ensuring that the following safeguards are implemented:

• Transferring your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data;
• Using the UK International Data Transfer Addendum or EU Standard Contractual Clauses;
• Verification of vendor GDPR certifications; and
• Annual risk and security assessments.

10. Data Retention

We retain data only for as long as necessary to meet legal, contractual, and operational 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.

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.

The table below sets out details of our retention periods:

11. Security Measures

We apply appropriate technical and organisational controls to protect personal data, including:

• TLS 1.2+ encryption in transit and encryption at rest.
• Multi-factor authentication for all internal systems.
• Role-based access controls and audit logging.
• Regular penetration testing and data security audits.
• Confidentiality agreements for staff and consultants.
• Restricted access to AML and verification data.

Security measures are reviewed at least annually and updated in response to emerging threats or changes in processing activities.

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.

12. Data Subject Rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “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.
• 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.
• Request erasure of your personal data in certain circumstances. 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.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• 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.
• 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.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• If you want us to establish the data’s accuracy;
• Where our use of the data is unlawful but you do not want us to erase it;
• 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; or
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

To exercise these rights, contact us at data@virtuallythereoffices.co.uk. 

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.

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.

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.

You also have the right to complain to the Information Commissioner’s Office (ICO) at www.ico.org.uk if you believe your data has been handled unlawfully. However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand.

13. Changes to This Policy

We may update this Privacy Policy to reflect changes in law or our business operations. Significant changes will be notified via our website or portal.
Please review this Policy periodically to stay informed.

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, for example a new address or email address.

14. Third-Party Links

Our website and portal 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.

Contact Us
Data Protection Lead – Virtually There Offices Limited
2.1a Temple Studios, Temple Gate, Bristol, BS1 6QA
data@virtuallythereoffices.co.uk

For more detail on our data governance practices, technical safeguards, and retention controls, please visit our Privacy & Data Governance page.”