Privacy Policy

Last updated: 26 August 2026

This privacy policy applies between you, the User of this Website, and Virtual Pursers® LLP, the owner and provider of this Website. Virtual Pursers® LLP takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us, or provided by you, in relation to your use of the Website.

This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found at: www.virtualpursers.com/terms-of-use.

Please read this privacy policy carefully.

1. Definitions and interpretation

In this privacy policy, the following definitions are used:

Data

collectively all information that you submit to Virtual Pursers® LLP via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Cookies

a small text file placed on your computer or device by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the section below headed “Cookies”;

Data Protection Laws

any applicable law relating to the processing of personal data, including but not limited to the UK GDPR and the Data Protection Act 2018 (in the United Kingdom); Regulation (EU) 2016/679 (the EU General Data Protection Regulation) and any national implementing laws in the European Economic Area; and the Privacy Act 1988 (Cth) and the Australian Privacy Principles (in Australia), in each case together with any related regulations, secondary legislation and codes of practice, as amended or replaced from time to time;

UK GDPR

the retained EU law version of the General Data Protection Regulation (Regulation (EU) 2016/679) as it forms part of the law of England and Wales, Scotland and Northern Ireland, together with the Data Protection Act 2018;

EU GDPR

the General Data Protection Regulation (Regulation (EU) 2016/679) as applicable in the European Economic Area;

Privacy Act

the Privacy Act 1988 (Cth) of Australia, including the Australian Privacy Principles (APPs) set out in Schedule 1 to that Act;

APPs

the Australian Privacy Principles contained in the Privacy Act, which govern the way in which personal information is collected, used, disclosed, stored and accessed;

ICO

the Information Commissioner’s Office, the United Kingdom’s supervisory authority for data protection;

OAIC

the Office of the Australian Information Commissioner, Australia’s regulator for privacy and freedom of information;

We or Us

Virtual Pursers® LLP, of 13 Whitchurch Lane, Edgware, Middlesex, London, HA8 6JZ, United Kingdom;

Cookie Law

the relevant provisions governing the use of cookies and similar technologies, including the UK Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended) and, in Australia, the requirements of the Privacy Act as they apply to online tracking;

User or you

any third party that accesses the Website and is not either (i) employed by Virtual Pursers® LLP and acting in the course of their employment, or (ii) engaged as a consultant or otherwise providing services to Virtual Pursers® LLP and accessing the Website in connection with the provision of such services; and

Website

the website that you are currently using, www.virtualpursers.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

Interpretation

In this privacy policy, unless the context requires a different interpretation:

• the singular includes the plural and vice versa;
• references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
• a reference to a person includes firms, companies, government entities, trusts and partnerships;
• “including” is understood to mean “including without limitation”;
• any reference to a statutory provision includes any modification, amendment, re-enactment or replacement of it; and
• the headings and subheadings do not form part of this privacy policy.

2. Scope of this privacy policy

This privacy policy applies only to the actions of Virtual Pursers® LLP and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website, including, but not limited to, any links we may provide to social media websites.

3. Who is responsible for your Data

For the purposes of the UK GDPR and the EU GDPR, Virtual Pursers® LLP is the “data controller”. For the purposes of the Privacy Act, Virtual Pursers® LLP is the “APP entity” responsible for the personal information it holds. This means that Virtual Pursers® LLP determines the purposes for which, and the manner in which, your Data is processed.

4. Data we collect

We may collect the following Data, which may include personal Data (and, in some cases, sensitive information), from you:

• name;
• date of birth;
• gender;
• job title and profession;
• contact information such as email addresses and telephone numbers;
• demographic information such as postcode, preferences and interests;
• financial information such as credit or debit card details (processed securely by our payment providers);
• IP address (automatically collected);
• web browser type and version (automatically collected);
• operating system (automatically collected);
• a list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected); and
• any other information reasonably necessary to enable us to efficiently provide our services to you or to our clients,

in each case in accordance with this privacy policy.

5. How we collect Data

We collect Data in the following ways: Data is given to us by you; Data is received from other sources; and Data is collected automatically.

Data given to us by you

Virtual Pursers® LLP will collect your Data in a number of ways, for example:

• when you contact us through the Website, by telephone, post, email or through any other means;
• when you register with us and set up an account to receive our products or services;
• when you complete surveys that we use for research purposes (although you are not obliged to respond to them);
• when you enter a competition or promotion through a social media channel;
• when you make payments to us, through this Website or otherwise;
• when you elect to receive marketing communications from us; and
• when you use our services,

in each case in accordance with this privacy policy.

Data received from third parties

Virtual Pursers® LLP may receive Data about you from the following third parties:

• websites;
• social media networks;
• surveys;
• subscription services; and
• website browsing activities.

We may also receive Data about you from the following publicly available third-party sources: government, agencies and affiliates; social media accounts; websites; and surveys.

Data collected automatically

To the extent that you access the Website, we will collect your Data automatically. For example, we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website, and the way you use and interact with its content.

We will also collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below headed “Cookies”.

6. Our use of Data

Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

• internal record keeping;
• improvement of our products and services;
• transmission by email of marketing materials that may be of interest to you; and
• contact for market research purposes, which may be carried out using email, telephone or mail, and which may be used to customise or update the Website,

in each case in accordance with this privacy policy.

Under the UK GDPR and the EU GDPR, we must always have a lawful basis for processing your Data. The lawful bases on which we rely include: the performance of a contract with you (or to take steps at your request before entering into a contract); compliance with a legal obligation; your consent; and our legitimate interests, provided these are not overridden by your rights and interests. Under the Privacy Act, we collect, hold, use and disclose your personal information in accordance with the Australian Privacy Principles.

If we rely on our legitimate interests to use your Data and you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).

7. Marketing

For the delivery of direct marketing to you via email, we will rely on your consent, whether via an opt-in or a soft opt-in:

• Soft opt-in consent applies where you have previously engaged with us (for example, you contact us to ask for more details about a particular product or service, and we are marketing similar products or services). Under soft opt-in consent, we will take your consent as given unless you opt out.
• For other types of e-marketing, we will obtain your explicit consent; that is, you will need to take a positive and affirmative action when consenting, for example by checking a tick box that we provide.

Every marketing communication we send will include a simple means of opting out. If you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.

8. Automated decision-making and use of artificial intelligence

Virtual Pursers® LLP may use approved artificial intelligence and automation tools to support administrative functions, research, drafting, data organisation and internal business processes. Where these technologies are used, we maintain appropriate human oversight and take reasonable steps to protect personal and confidential information.

We do not use solely automated processing, including generative AI, to make decisions that produce legal effects or otherwise significantly affect crew, clients or other individuals. A person is always involved in decisions of that kind.

Where we do use computer programs or systems to make, or substantially help to make, decisions that could significantly affect your rights or interests, we will tell you about this in accordance with applicable Data Protection Laws, including the transparency requirements introduced by the Australian Privacy and Other Legislation Amendment Act 2024. You may contact us at any time to ask about how any such decision was made.

9. Who we share Data with

We may share your Data with the following groups of people for the following reasons:

• our group companies and affiliates — to assist in providing our services and to support the running of our business;
• our employees, agents and/or professional advisers — to deliver our services efficiently and to obtain professional advice where needed;
• third-party service providers who provide services to us that require the processing of personal data — to help ensure that our Website and services run smoothly and are directed to those who need them;
• third-party payment providers who process payments made over the Website — to enable them to process user payments and refunds;
• relevant authorities — to facilitate the detection or prevention of crime, the collection of amounts owed to us, or compliance with any legal obligation, and to address any breach of a contract, our terms and conditions, this privacy policy or any other legal document provided by Virtual Pursers® LLP,

in each case in accordance with this privacy policy. Where we share your personal information with third parties, we take reasonable steps to ensure they are bound by appropriate confidentiality and data protection obligations.

10. Keeping Data secure

We will use technical and organisational measures to safeguard your Data, for example:

• access to your account is controlled by a password and a user name that is unique to you;
• we store your Data on secure servers; and
• payment details are encrypted using SSL/TLS technology (typically you will see a padlock icon in the address bar of your browser when we use this technology).

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse, loss of, or unauthorised access to your Data, please let us know immediately by contacting us at purser@virtualpursers.com.

For detailed information on how to protect your information, your computers and your devices against fraud, identity theft, viruses and other online problems, you may wish to visit www.getsafeonline.org (supported by HM Government and leading businesses) or, in Australia, the Australian Cyber Security Centre at www.cyber.gov.au.

11. Data breaches

We take our obligations in relation to data breaches seriously. Where we are legally required to do so, we will notify the relevant supervisory authority and any affected individuals of an eligible data breach. In the United Kingdom this means notifying the ICO in line with the UK GDPR; in Australia this means complying with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act 1988 (Cth), which requires us to notify the OAIC and affected individuals of eligible data breaches that are likely to result in serious harm.

12. Data retention

Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this privacy policy or until you request that the Data be deleted. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

13. Your rights

Depending on where you are located and the Data Protection Laws that apply to you, you have some or all of the following rights in relation to your Data:

• Right to access — the right to request copies of the information we hold about you at any time, or that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is manifestly unfounded or excessive. Where we are legally permitted to do so, we may refuse your request, in which case we will tell you the reasons why.
• Right to correct — the right to have your Data rectified if it is inaccurate or incomplete.
• Right to erase — the right to request that we delete or remove your Data from our systems.
• Right to restrict our use of your Data — the right to “block” us from using your Data or to limit the way in which we can use it.
• Right to data portability — the right to request that we move, copy or transfer your Data.
• Right to object — the right to object to our use of your Data, including where we use it for our legitimate interests.
• Right to complain — the right to lodge a complaint with the relevant data protection authority (see the section below).

If you are located in Australia, these rights operate in the manner provided for under the Australian Privacy Principles, including your right to seek access to, and correction of, the personal information we hold about you.

14. How to make an enquiry or complaint

To make an enquiry, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing), please contact us at purser@virtualpursers.com. We will respond to your request within the timeframes required by the applicable Data Protection Laws.

If you are not satisfied with the way in which we handle a complaint relating to your Data, you may refer your complaint to the relevant data protection authority:

• United Kingdom / EEA: the Information Commissioner’s Office (ICO). The ICO’s contact details can be found at ico.org.uk.
• Australia: the Office of the Australian Information Commissioner (OAIC), by telephone on 1300 363 992 or via www.oaic.gov.au.

15. International transfers of Data

Because we operate internationally, Data which we collect from you may be stored and processed in, and transferred to, countries outside the country in which you are located — including outside the United Kingdom, the European Economic Area (EEA) and Australia. For example, this may occur where our servers or one of our service providers is located in another country, or where we share information with our group companies.

We will only transfer your Data internationally where the transfer complies with the applicable Data Protection Laws and where appropriate safeguards are in place. Depending on the transfer, these safeguards may include an adequacy decision, the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the European Commission’s standard contractual clauses, the EU standard contractual clauses, or, in respect of transfers to the United States, reliance on the EU–US Data Privacy Framework and its UK Extension. In relation to transfers from Australia, we take reasonable steps to ensure that overseas recipients handle your personal information in accordance with the Australian Privacy Principles.

This ensures that your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

16. Keeping your Data current

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

17. Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of any other website prior to using it.

18. Changes of business ownership and control

Virtual Pursers® LLP may, from time to time, expand or reduce our business, and this may involve the sale and/or the transfer of control of all or part of Virtual Pursers® LLP. Data provided by Users will, where it is relevant to any part of our business that is transferred, be transferred along with that part, and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business, or any part of it. In each of the above instances, we will take steps with the aim of ensuring that your privacy is protected.

19. Cookies

This Website may place and access certain Cookies on your computer or device. Virtual Pursers® LLP uses Cookies to improve your experience of using the Website and to improve our range of services. Virtual Pursers® LLP has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current Cookie Law. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Virtual Pursers® LLP to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however, certain features of the Website may not function fully or as intended.

This Website may place the following Cookies:

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept cookies, but this can be changed. For further details, please consult the help menu in your internet browser. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently, including, but not limited to, personalisation settings.

It is recommended that you ensure your internet browser is up to date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

20. General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This privacy policy will be governed by and interpreted according to the law of England and Wales, and disputes arising under it will be subject to the exclusive jurisdiction of the courts of England and Wales. Nothing in this privacy policy limits or excludes any rights you may have under the mandatory data protection or consumer laws that apply to you, including, where applicable, the Australian Privacy Act 1988 (Cth).

21. Changes to this privacy policy

Virtual Pursers® LLP reserves the right to change this privacy policy as we may deem necessary from time to time, or as may be required by law. Any changes will be immediately posted on the Website, and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.