This Policy sets out the obligations of VOX Studios regarding data privacy and the rights of consumers in respect of their personal information under the Virginia Consumer Data Protection Act (VCDPA) and applicable U.S. law.The VCDPA defines "personal data" as any information that is linked or reasonably linkable to an identified or identifiable natural person. This does not include de-identified data or publicly available information.This Policy outlines the procedures to be followed when handling personal data. These procedures and principles must be followed at all times by VOX Studios, its employees, agents, contractors, or other parties working on behalf of the business.VOX Studios is committed not only to the letter of the law, but also to the spirit of the law, and places high importance on the correct, lawful, and fair handling of all personal information, respecting the privacy and trust of all individuals with whom it engages.

This Policy aims to ensure compliance with the Virginia Consumer Data Protection Act (VCDPA) and applicable U.S. federal privacy laws. VOX Studios is committed to collecting and using personal data in a manner that respects individuals' rights, ensures data integrity, and maintains transparency and security. All personal data must be:a) Collected and used with transparency and fairness, and only with the individual's consent or as otherwise permitted by law; b) Collected for specific, clear, and legitimate purposes, and not used in ways that are incompatible with those purposes; c) Adequate, relevant, and limited to what is necessary in relation to the purposes for which it is used; d) Accurate and, where necessary, kept up to date; reasonable steps will be taken to correct or delete inaccurate information; e) Retained only for as long as necessary to fulfill the purposes for which it was collected, unless otherwise required by law; f) Secured using appropriate administrative, technical, and physical safeguards to prevent unauthorized access, use, or disclosure.

The VCDPA seeks to ensure that personal data is collected and used lawfully, fairly, and transparently, without adversely affecting the rights of the consumer. The law states that use of personal data is lawful if at least one of the following applies:a) The consumer has given consent for one or more specific purposes; b) Use is necessary for the performance of a contract with the consumer or to take steps at their request before entering into a contract; c) Use is necessary for compliance with a legal obligation; d) Use is necessary to protect vital interests of the individual or another person; e) Use is necessary to carry out a task in the public interest; f) Use is necessary for the legitimate interests of the business, provided those interests are not overridden by the rights and freedoms of the consumer.

4.1 The Company collects and processes the personal data set out in Part 21 of this Policy. This may include personal data received directly from data subjects (for example, contact details used when a data subject communicates with us).
4.2 The Company only processes personal data for the specific purposes set out in Part 21 of this Policy (or for other purposes expressly permitted by the Regulation). The purposes for which we process personal data will be informed to data subjects at the time that their personal data is collected, where it is collected directly from them, or as soon as possible (not more than one calendar month) after collection where it is obtained from a third party.

The Company will only collect and process personal data for and to the extent necessary for the specific purpose(s) informed to data subjects as under Part 4, above.

The Company shall ensure that all personal data collected and processed is kept accurate and up-to-date. The accuracy of data shall be checked when it is collected and at regular intervals thereafter. Where any inaccurate or out-of-date data is found, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

The Company shall not keep personal data for any longer than is necessary in light of the purposes for which that data was originally collected and processed. When the data is no longer required, all reasonable steps will be taken to erase it without delay.

The Company shall ensure that all personal data collected and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction or damage. Further details of the data protection and organisational measures which shall be taken are provided in Parts 22 and 23 of this Policy.

9.1 The Company’s Data Protection Officer is Stephen Bement info@voxstudios.com.
9.2 The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:
a) The name and details of the Company, its data protection officer, and any applicable third party data controllers;
b) The purposes for which the Company processes personal data;
c) Details of the categories of personal data collected, held, and processed by the Company; and the categories of data subject to which that personal data relates;
d) Details (and categories) of any third parties that will receive personal data from the Company;
e) Details of any transfers of personal data to non-EEA countries including all mechanisms and security safeguards;
f) Details of how long personal data will be retained by the Company; and
g) Detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of personal data.

The Company shall carry out Privacy Impact Assessments when and as required under the Regulation. Privacy Impact Assessments shall be overseen by the Company’s data protection officer and shall address the following areas of importance:
10.1 The purpose(s) for which personal data is being processed and the processing operations to be carried out on that data;
10.2 Details of the legitimate interests being pursued by the Company;
10.3 An assessment of the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;
10.4 An assessment of the risks posed to individual data subjects; and
10.5 Details of the measures in place to minimise and handle risks including safeguards, data security, and other measures and mechanisms to ensure the protection of personal data, sufficient to demonstrate compliance with the Regulation.

The Regulation sets out the following rights applicable to data subjects:
a) Right to access personal data;
b) Right to delete data;
c) Right to correct inaccuracies;
d) Right to obtain a copy (data portability);
e) Right to opt out of data sales or targeted advertising;

12.1 The Company shall ensure that all individuals (data subjects) are provided with the following information at the time their personal data is collected, or as soon as practicable thereafter:a) The identity and contact details of the Company and its Data Protection Officer (DPO);
b) The purpose(s) for which the personal data is being collected and used, and the legal basis for the processing;
c) Where applicable, the Company’s legitimate interests for processing the data;
d) If the data was not collected directly from the data subject, the categories of personal data obtained;
e) The categories of third parties with whom personal data may be shared;
f) Whether personal data will be transferred to another country and the safeguards that are in place for such transfers, if any;
g) The period for which the personal data will be retained, or the criteria used to determine that period;
h) The rights of the data subject under the VCDPA, including the right to access, correct, delete, or opt out of the processing of their personal data;
i) The right to withdraw consent at any time, where applicable;
j) The right to lodge a complaint with the Virginia Attorney General if the data subject believes their rights under the VCDPA have been violated;
k) Whether the provision of personal data is required by law or contract, and any consequences of failing to provide the data;
l) The existence of automated decision-making, if any, including profiling, and meaningful information about the logic involved and the potential consequences.12.2 This information shall be provided to data subjects as follows:12.2.1 If the data is collected directly from the data subject, at the time of collection;
12.2.2 If the data is collected from another source:
a) At the time of the first communication with the data subject; or
b) Before the data is shared with a third party; or
c) Within a reasonable time after obtaining the data, but no later than 30 days.

13.1 A consumer may submit a request at any time to learn what personal data VOX Studios holds about them. The business is normally required to respond within 45 days of receiving the request (which may be extended once by an additional 45 days when reasonably necessary, provided the consumer is informed of the extension).13.2 All access requests received must be forwarded to the VOX Studios privacy team or designated privacy manager.13.3 VOX Studios does not charge a fee for handling standard access requests. The business reserves the right to charge a reasonable fee or decline a request if it is manifestly unfounded, excessive, or repetitive.

14.1 If a consumer informs VOX Studios that personal data held by the business is inaccurate or incomplete, the business will correct that data and inform the consumer within 45 days of receiving the request (which may be extended as outlined in Section 13).14.2 If corrected personal data has been shared with service providers or other parties, VOX Studios will notify them where feasible.

15.1 Data subjects may request that the Company erases the personal data it holds about them in the following circumstances:
a) It is no longer necessary for the Company to hold that personal data with respect to the purpose for which it was originally collected or processed;
b) The data subject wishes to withdraw their consent to the Company holding and processing their personal data;
c) The data subject objects to the Company holding and processing their personal data (and there is no overriding legitimate interest to allow the Company to continue doing so) (see Part 18 of this Policy for further details concerning data subjects’ rights to object);
d) The personal data has been processed unlawfully;
e) The personal data needs to be erased in order for the Company to comply with a particular legal obligation;
15.2 Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request (this can be extended by up to two months in the case of complex requests, and in such cases the data subject shall be informed of the need for the extension).
15.3 In the event that any personal data that is to be erased in response to a data subject request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

16.1 Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data pertaining to that data subject that is necessary to ensure that no further processing of their personal data takes place.
16.2 In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

17.1 Data subjects have the right to object to the Company processing their personal data based on legitimate interests (including profiling), direct marketing (including profiling), and processing for scientific and/or historical research and statistics purposes.
17.2 Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing forthwith, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights and freedoms; or the processing is necessary for the conduct of legal claims.
17.3 Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing forthwith.
17.4 Where a data subject objects to the Company processing their personal data for scientific and/or historical research and statistics purposes, the data subject must, under the Regulation, ‘demonstrate grounds relating to his or her particular situation’. The Company is not required to comply if the research is necessary for the performance of a task carried out for reasons of public interest.

VOX Studios does not use fully automated decision-making that produces legal or similarly significant effects.

Where the Company uses personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling (see Parts 22 and 23 of this Policy for more details on data security).

The following personal data may be collected, held, and processed by the Company:
a) Basic contact information including name, email address, telephone number, for the purpose of marketing and promotional correspondence to new and existing customers;
b) Personal information, contact details, billing & banking details, business details, in order to place bookings and take payments from customers, or when soliciting services from suppliers;
c) Personal contact information, banking information, employment records, and other sensitive information such as family and health circumstances, explicitly and strictly of those employed by the Company, kept in confidential, restricted-access Staff Records;
d) Banking information and transaction records, when making sales, paying suppliers or for internal payroll;
e) CCTV live footage monitored and recorded, for crime prevention, maintaining the security of property and premises, for investigating crime and identification of persons of interest pertaining to legal or criminal investigation;

The Company shall ensure that all its employees, agents, contractors, or other parties working on its behalf comply with the following when working with personal data:
a) Where any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. Hardcopies should be shredded, and electronic copies should be deleted securely.
b) Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;
c) Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;
d) Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;
e) Where Personal data is to be transferred in hardcopy form it should be passed directly to the recipient or sent using registered mail or private courier;
f) No personal data may be shared informally and if an employee, agent, sub-contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from our Data Protection Officer;
g) All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet or similar;
h) No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without the authorisation of our Data Protection Officer;
i) Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, sub-contractors or other parties at any time;
j) If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;
k) No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets and smartphones), whether such device belongs to the Company or otherwise without the formal written approval of our Data Protection Officer and, in the event of such approval, strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary.
l) No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the Regulation (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);
m) All personal data stored electronically should be backed up daily with backups stored onsite.
n) All electronic copies of personal data should be stored securely;;
o) All passwords used to protect personal data should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols;
p) Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
q) Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of our, Data Protection Officer, to ensure that no data subjects have added their details to any marketing preference databases including, but not limited to, the Telephone Preference Service, the Mail Preference Service, the Email Preference Service, and the Fax Preference Service. Such details should be checked regularly.

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:
a) All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the Regulation and under this Policy, and shall be provided with a copy of this Policy;
b) Only employees, agents, sub-contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;
c) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
d) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;
e) Methods of collecting, holding and processing personal data shall be regularly evaluated and reviewed;
f) The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
g) All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of the Regulation and this Policy by contract;
h) All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and the Regulation;
i) Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

23.1 The Company may from time to time transfer (‘transfer’ includes making available remotely) personal data to countries outside of the USA.23.2 The transfer of personal data to a country outside of the USA shall take place only if one or more of the following applies:a) The transfer is to a country, territory, or one or more specific sectors in that country (or an international organisation), that is recognized under applicable U.S. law or industry standards as providing an adequate level of protection for personal data;b) The transfer is to a country (or international organisation) which provides appropriate safeguards in the form of a legally binding agreement between public authorities or bodies; binding corporate rules; standard data protection clauses; compliance with an approved code of conduct; certification under an approved certification mechanism; contractual clauses agreed and authorised by the Company’s legal counsel; or provisions inserted into administrative arrangements between public authorities or bodies;c) The transfer is made with the informed consent of the relevant data subject(s);d) The transfer is necessary for the performance of a contract between the data subject and the Company (or for pre-contractual steps taken at the request of the data subject);e) The transfer is necessary for important public interest reasons;f) The transfer is necessary for the conduct of legal claims;g) The transfer is necessary to protect the vital interests of the data subject or other individuals where the data subject is physically or legally unable to give their consent; orh) The transfer is made from a register that, under U.S. law, is intended to provide information to the public and which is open for access by the public in general or otherwise to those who are able to show a legitimate interest in accessing the register.

24.2 If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the data protection officer must ensure that we notify the Virginia Attorney General and affected individuals as required by state law and without undue delay, and in any event, within 72 hours after having become aware of it.
24.3 In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 25.2) to the rights and freedoms of data subjects, the data protection officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.
24.4 Data breach notifications shall include the following information:
a) The categories and approximate number of data subjects concerned;
b) The categories and approximate number of personal data records concerned;
c) The name and contact details of the Company’s data protection officer (or other contact point where more information can be obtained);
d) The likely consequences of the breach;
e) Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where appropriate, measures to mitigate its possible adverse effects.

24.1 All personal data breaches must be reported immediately to the Company’s data protection officer.