Privacy Policy - Including Cookie Policy

Virtuoso QA is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our website, software, or services, and how you can exercise your data protection rights.

1. Who We Are

Company name: SpotQA Ltd trading as ‘Virtuoso QA’ (“Virtuoso QA”, “we”, “us”)
Registered office address: International House, 64 Nile Street, London, N1 7JR
Data protection contact: privacy@virtuosoqa.com

2. Scope

This policy applies where we are acting as a data controller (in other words, where we determine the purposes and means of the processing of that personal data) with respect to the personal data of:

• Our website visitors and service users
• Customers, clients, and service recipients of our software and services
• Job applicants and prospective employees

It applies to personal data collected:

• Through our website and web applicables
• From customers, users and job applicants
• Through communications with our team
• From third party systems we integrate with

This policy does not apply where we act as data processor with respect to our customers and users which shall be governed by the relevant Data Processing Agreement between us.

3. Personal Data We Collect

We collect personal data in three main ways:

• Name, email address, phone number
• Company details and account information
• Service requests and support communications
• Job application information including CVs/resumes, cover letters, employment history, education, references, and interview notes

• IP address, browser type, device information
• Usage analytics and cookies

• CRM systems, marketing platforms, and business partners
• Communication data obtained from third-party platforms we integrate with (such as call transcripts, meeting notes, and associated metadata including participants, timestamps, and interaction context).

We do not collect any special categories of personal data about you, nor do we collect any information about criminal convictions and offences.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Provide and maintain our services
• Respond to inquiries and support requests
• Send service updates or marketing communications (where consented)
• Improve our website, software, and services
• Ensure security and prevent misuse
• Assess and process job applications, manage recruitment processes, and, where relevant, manage employment relationships
• Analyse business communications (such as sales calls and related transcripts) to understand customer needs, improve our sales processes, and inform product development and commercial strategy.

We will never sell your personal data.

5. Legal Basis for Processing

We rely on the following lawful bases under UK GDPR:

• Contract: To deliver services you request
• Legitimate Interests: Improving and developing our products and services, including analysing business communications to understand user needs, market expectations, and product performance, ensuring security, managing relationships, recruiting and assessing candidates, the proper protection of our business against risks, and the protection and assertion of our legal rights, your legal rights and the rights of others.
• Consent: For marketing communications
• Legal Obligation: To comply with UK law or regulatory requirements

6. Sharing Your Personal Data

We may share personal data with:

• Other companies in the same group as Virtuoso QA.
• Service providers and suppliers acting under our instructions and subject to contractual data protection obligations, including cloud hosting and IT service providers, analytics, providers of artificial intelligence and data analysis services used to support internal business analytics and product improvement, recruitment platforms, CRM, and marketing service providers. A current list of our sub-processors is available here.
• Legal, regulatory, and professional advisers
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We only share your personal information when it is necessary, lawful and proportionate to do so. We ensure any third parties who receive your information are bound by strict confidentiality and data protection obligations. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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.

7. International Transfers

If personal data is transferred outside the UK, we implement safeguards such as standard contractual clauses or transfers to countries deemed to provide adequate protection by UK law.

8. Data Security

We use appropriate technical and organisational measures to protect personal data, including:

• Encryption and access controls
• Secure infrastructure and software
• Monitoring and logging
• Staff training on data protection

9. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting 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.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes. After this, personal data is securely deleted or anonymised.

In some circumstances you can ask us to delete your data: see below for further information.

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.

10. Your Data Protection Rights

You have the right to:

• Access your personal data
• Request correction or deletion
• Restrict processing
• Object to processing
• Receive your data in a portable format
• Withdraw consent at any time

If you consider that our processing of your personal information infringes data protection laws, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

To exercise your rights, please contact us at privacy@virtuosoqa.com

11. Cookies and Tracking

We use cookies on our website. Cookies are not necessary for the provision of www.virtuosoqa.com or our services but we will ask you to consent to our use of cookies when you first visit our website.

We use cookies and tracking technologies to:

• Ensure website functionality
• Analyse website usage
• Deliver marketing communications (with consent)

Our third party service providers use cookies and those cookies may be stored on your computer when you visit our website. We are not in control of the specific cookies placed by these third parties. However, we have tried to give you some helpful information in our Privacy Preference Centre which you can access by clicking on the Cookie Settings link.

You can manage your cookie preferences in your browser at any time.

12. Use of Artificial Intelligence

We may use automated tools, including artificial intelligence (“AI”), to support the delivery, improvement, and security of our website, software, and services.

These tools may be used to:

• Analyse usage data and improve product performance and user experience
• Assist with customer support and service delivery
• Support recruitment processes (for example, reviewing applications)
• Analyse business communications, such as sales call transcripts and related metadata, to identify patterns, trends, and insights that help us improve our products, services, and commercial operations.
• Enhance security, detect misuse, and prevent fraud

Where AI tools are used, they operate as supporting tools to our teams and are subject to appropriate human oversight. Commercial analysis undertaken by AI tools is carried out at an aggregated level wherever possible and is not used to make decisions about specific individuals. We implement measures to reduce identifiability, including avoiding the use of unnecessary personal data and limiting the inclusion of identifiable information in outputs. We do not rely solely on automated decision-making that produces legal or similarly significant effects on individuals without appropriate safeguards.

AI tools may process personal data where necessary for the purposes described in this Privacy Policy. In such cases:

• Processing is carried out in accordance with the lawful bases set out in Section 5
• We implement appropriate technical and organisational measures to protect personal data
• Any third-party AI service providers are subject to contractual data protection obligations, as described in Section 6
• Where AI involves the processing of personal data outside the UK, we ensure appropriate safeguards are in place in accordance with Section 7.

We are committed to using AI responsibly, transparently, and in line with applicable data protection laws.

13. Data Protection Complaints

If you have concerns about how we process your personal data, you can:

Email: privacy@virtuosoqa.com

If you are not satisfied with our response, you may contact the UK’s data protection regulator, the Information Commissioner’s Office, at https://ico.org.uk/make-a-complaint/

14. Changes to This Policy

We may update this policy from time to time. The latest version will always be published on our website.

15. Contact Us

Email: privacy@virtuosoqa.com
Address: International House, 64 Nile Street, London, N1 7JR

Last updated April 2026