Privacy Policy

Little Gem VA Business Services (the “Company”) is committed to maintaining robust privacy

protections for its users. Our Privacy Policy (“Privacy Policy”) is designed to help you understand
how we collect, use and safeguard the information you provide to us and to assist you in making
informed decisions when using our Service.

For purposes of this Agreement, “Site” refers to the Company’s website, which can be accessed

“Service” refers to the Company’s services accessed via the Site, in which users can review the
administrative services available and contact us to make an enquiry.

The terms “we,” “us,” and “our” refer to the Company.
“You” refers to you, as a user of our Site or our Service.

By accessing our Site or our Service, you accept our Privacy Policy and Terms of Use (found
below), and you consent to our collection, storage, use and disclosure of your Personal
Information as described in this Privacy Policy.


Information we Collect
Little Gem VA Business Services collects “Non-Personal Information” and “Personal Information”
in the categories described below.


Usage data
Little Gem VA Business Services will process information about your use of our website and
services (“usage data”). The usage data may include
(1) the browser types and versions used
(2) the operating system used by the accessing system
(3) the website from which an accessing system reaches our website (so-called referrers)
(4) the sub-websites
(5) the date and time (so-called timestamp) of access to the Internet site
(6) an Internet protocol address (IP address)
(7) the Internet service provider (ISP) of the accessing system
(8) the geographical location of the user
(9) the page views and site navigation paths
(10) the pattern of the users’ use of the service with regards to timing and frequency
(11) any other similar data and information that may be used in the event of attacks on our
information technology systems.

The source of the usage data is Google Analytics. The usage data collected is needed to
(1) deliver the content of our website correctly
(2) optimise the content of our website as well as any advertisement
(3) ensure the long-term viability of our information technology systems and website technology
(4) provide law enforcement authorities with the information necessary for criminal prosecution
in case of a cyber-attack.


Google Analytics stores information about:
 The pages you visit
 How long you spend on each page
 How you got to the site
 What you click on while you’re visiting the site

We don’t collect or store your personal information (for example your name or address) so this
information can’t be used to identify who you are and we don’t allow Google to use or share our
analytics data.

You can opt out of Google Analytics cookies.

In order to process this information, we have obtained the user’s consent and it is in our
legitimate interests in monitoring and improving our website and services.


Notification data
Little Gem VA Business Services may process information that you provide to us for the purpose
of subscribing to our email notifications and/or newsletters (“notification data”). Our newsletter
may only be received by the user if
 the user has a valid email address and
 the user registers for the newsletter shipping.

A confirmation email will be sent to the email address registered by a user for the first time for
newsletter shipping, for legal reasons, in a double opt-in procedure. The confirmation email is
used to prove whether the owner of the email address as the user is authorised to receive the

When the user registers for the newsletter, we also store the IP address of the computer system
assigned by the Internet service provider (ISP) and used by the user at the time of the
registration, as well as the date and time of the registration. The purpose of the collection of
this data is to legally protect Little Gem VA Business Services by ensuring understanding of the
possible misuse of the email address of a user at a later date. The personal information
collected as part of a registration for the newsletter will only be used to send our newsletter.

The subscription to the newsletter may be terminated by the user at any time. The consent to
the storage of personal data, which the user has given prior to the shipping of the newsletter,
may be revoked at any time. For the purpose of revoking consent, a corresponding link for
unsubscribing is found in each newsletter.


Enquiry data, correspondence data and customer relationship data
Little Gem VA Business Services may process information contained in any enquiry you submit
to us regarding our services and products (“enquiry data”). If a user contacts us via email or via
a contact form, the personal information transmitted by the user is automatically stored.
The personal information may include:
(1) the user’s contact information
(2) the user’s name
(3) the name of the user’s employer
(4) the user’s job title or role
(5) the metadata associated with the communication
(6) and information contained in communications between the user and Little Gem VA Business

Such personal data transmitted on a voluntary basis by a user to Little Gem VA Business
Services are stored for the purpose of processing or contacting the user, managing our
relationships with customers, keeping records of communication with the user, and promoting
our products and services to customers.


Publication data
Little Gem VA Business Services may process information that the users post for publication on
our website or through our services (“publication data”). On our website the users can post
information in the following ways: blog comments, forum posts, etc.


How we use and share Information
Personal Information
Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share
for marketing purposes your Personal Information with third parties without your consent. We
do share Personal Information with vendors who are performing services for the Company, such
as the servers for our email communications who are provided access to user’s email address for
purposes of sending emails from us. Those vendors use your Personal Information only at our
direction and in accordance with our Privacy Policy.

In general, the Personal Information you provide to us is used to help us communicate with you.
For example, we use Personal Information to contact users in response to questions, solicit
feedback from users, provide technical support, and inform users about promotional offers.


Non-Personal Information
In general, we use Non-Personal Information to help us improve the Service and customise the
user experience. We also aggregate Non-Personal Information in order to track trends and
analyse use patterns on the Site. This Privacy Policy does not limit in any way our use or
disclosure of Non-Personal Information and we reserve the right to use and disclose such Non-
Personal Information to our partners, advertisers and other third parties at our discretion.
Legal purpose of the processing of personal data
Little Gem VA Business Services may process any of your personal information identified in this
privacy policy where necessary for the establishment, exercise or defence of legal claims, both in
court proceedings and in an administrative or out-of-court procedure. The legal basis for this
processing is the protection and assertion of our legal rights, your legal rights and the legal
rights of others.

Little Gem VA Business Services may also process any of your personal information identified in
this privacy policy where necessary for the purposes of obtaining or maintaining insurance
coverage, managing risks, fulfilment of tax obligations, or obtaining professional advice. The
legal basis for this processing is the proper protection of our business against risks.


Retaining and Deleting your Personal Information
The personal information that we process for any purpose or purposes will not be kept for
longer than is necessary for the expressed purpose. We will retain your personal data as follows:
 the user’s contact information
 the user’s name
 the user’s email address
 the user’s IP address
 the name of the user’s employer
 the user’s job title or role
 the metadata associated with the communication
 and information contained within communications between the user and Little Gem VA
Business Services
 will be retained for a minimum period of 6 months and for a maximum period of 5 years.

In some instances, it is not possible for us to specify in advance the periods for which your
personal information will be stored by us. In such cases, we will determine the period of retention
based on the following criteria:
 the period of retention of contact information (including email addresses and IP
 the period of retention of billing details
 the period of retention of information contained with communications between the user
and Little Gem VA Business Services will be determined based on the term you are a
client with us.


If you are a resident of the EEA, you have the following data protection rights:
 If you wish to access, correct, update, or request deletion of your personal information,
you can do so at any time by emailing
 In addition, you can object to the processing of your personal information, ask us to
restrict the processing of your personal information or request portability of your
personal information.
 You have the right to opt-out of marketing communications we send you at any time. You
can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing
emails we send you. To opt-out of other forms of marketing, please contact us by emailing

 Similarly, if we have collected and process your personal information with your consent,
then you can withdraw your consent at any time. Withdrawing your consent will not affect
the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect
the processing of your personal information conducted in reliance on lawful processing
grounds other than consent.
 You have the right to complain to a data protection authority about our collection and
use of your personal information. For more information, please contact your local data
protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection
rights in accordance with applicable data protection laws.


Links to Other Websites
As part of the Service, we may provide links to or compatibility with other websites or
applications. However, we are not responsible for the privacy practices employed by those
websites or the information or content they contain. This Privacy Policy applies solely to
information collected by us through the Site and the Service. Therefore, this Privacy Policy does
not apply to your use of a third-party website accessed by selecting a link on our Site or via our
Service. To the extent that you access or use the Service through or on another website or
application, then the privacy policy of that other website or application will apply to your access
or use of that site or application. We encourage our users to read the privacy statements of
other websites before proceeding to use them.


We may update this policy from time to time by publishing a new version on our website. You
should check this page occasionally to ensure you are happy with any changes to this policy. We
may notify you of significant changes to this policy by email or by placing a prominent notice on
our site. Significant changes will go into effect 30 days following such notification. Non-material
changes or clarifications will take effect immediately. You should periodically check the Site and
this privacy page for updates.


Contact Us
This website is owned and operated by Little Gem VA Business Services.
Registered in the UK at the following address: 36 Belfast Avenue, Berkshire. SL1 3HL
If you have any questions regarding this Privacy Policy or the practices of this Site, please
contact us by sending an email to:
Privacy Policy was last updated on 1st January 2019