PRIVACY POLICY

Introduction

Welcome to VDK Capital’s privacy policy (“Privacy Policy”).

VDK Capital respects your privacy and is committed doing the right thing when it comes to protecting your personal data, including how we collect, use and protect your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you and specifically, aims to give you information on:

the types of personal data that we will collect;
why we will collect and use your personal data;
when and why we will share personal data with other organisations;
the rights and choices you have when it comes to your personal data; and
why and how it collects and processes your personal data through your use of its website, including any data you may provide through its website when you use any of the services by VDK Capital or invest in any of our products.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements any other privacy notices or policies and is not intended to override them.

Please take the time to read this Privacy Policy. If you have any questions about this Privacy Policy or our use of your information you can contact us at info@vdk.capital

This Privacy Policy may change from time to time and if it does, the up-to-date version will always be available on the website. Please note that by continuing to use our website, you are agreeing to any updated versions of our Privacy Policy.

Third party links

Our website may include links to third-party advertisers, affiliates, 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, notices or policies. When you leave our website, we encourage you to read the privacy notice of every website you visit. We do not accept any responsibility or liability for the privacy policies or notices on third-party websites. Please check these policies before you submit any personal data to these websites. 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.

Why we may collect data about you

There are many reasons why we may legitimately collect and process your personal information and data, including:

Consent In specific situations, we can collect and process your data with your consent.
Contractual obligations We may process your information where it is necessary to either enter into a contract with you for the provision of our products or services or to perform our obligations under that contract or to provide you with advice or guidance in relation to our products or services that are offered by us.
Legal compliance If the law or any regulator in any competent jurisdiction requires us to, we may need to collect and process your data and also provide this to any such regulator.
Legitimate interest We may process your information in the day to day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you.

How we may obtain your data and information

We may obtain information in several ways which may include:

Information which you give to us;
Information that we receive from third parties – including third parties who provide services to you or us (including Laven Advisors LLP, or via credit reference agencies, fraud prevention agencies or government agencies), and other banks (where permitted by law);
Information that we learn about you through our relationship with you and the way you operate your accounts and/or services, such as the payments made to and from your accounts;
Information that we gather from the technology which you use to access our services (for example an IP address or telephone number; and
Information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.

What information we may collect and process

We collect and process various categories of personal information and data at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of data and information to that which is necessary to achieve one or more legitimate purposes as identified in this Privacy Policy.

The types of personal information and data may include (but is not limited to):

basic personal information, including name and address, date of birth and contact details;
financial information, including account and transactional information and history;
information about your family, lifestyle and social circumstances (such as dependents, marital status, next of kin and contact details);
information about your financial circumstances, including personal wealth, assets and liabilities, proof of income and expenditure, credit and borrowing history and needs and goals;
education and employment information;
goods and services provided;
visual images and personal appearance (such as copies of passports or CCTV images); and
online profile and social media information and activity, based on your interaction with us and our websites and applications, including for example your banking profile and login information, Internet Protocol (IP) address, smart device information, location coordinates, online and mobile banking security authentication, mobile phone network information, searches, site visits and spending patterns.

Where permitted by law or to fulfil our regulatory requirements, we may process information about criminal convictions or offences and alleged offences for specific and limited activities and purposes, such as to perform checks to prevent and detect crime and to comply with laws relating to money laundering, fraud, terrorist financing, bribery and corruption, and international sanctions. It may involve investigating and gathering intelligence on suspected financial crimes, fraud and threats and sharing data between banks and with law enforcement and regulatory bodies.

How we use your information

We may use your personal information and/or data to:

Administer, operate, facilitate and manage your relationship and/or account with VDK Capital. This may include sharing such information internally as well as disclosing it to third parties;
Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, etc., in connection with your relationship and/or account;
Provide you with information relating to our products and services; and
Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with us ends, we will continue to treat your personal information, to the extent we retain it, as described in this Privacy Policy.

We do not sell or share your personal information and/or data to third parties for third party direct marketing purposes. We record telephone lines and other communications including mails, emails, or documentation of client orders. Copies of these recordings and/or other communications set out in this paragraph may be delivered to any court of or regulatory authority in a competent jurisdiction.

Disclosure of your information (including outside of the European Economic Area “EEA”)

When we share your information with third parties they will process your information as either a data controller or as our data processor and this will depend on the purposes of our sharing your personal data with such third party. We will only share your personal data in compliance with the applicable data protection laws and regulatory requirements.

We may disclose your information to third parties:

When you specifically request this, such as when you submit information to inquire about jobs;
When products and services may interest you provided we have your consent;
including buyers or sellers or any of our business or assets in which case;
To the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights.
If we sell our business or assets, or if we are acquired by a third party, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes.

We may transfer data with third-party agents and contractors for the purposes of providing services to us (for example, VDK Capital’s accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your personal information as described in this Privacy Policy.

We may share some broader statistics and customer profiling information with third parties, but the information or data will be anonymised, so you will not be identifiable from that data. We will not rent or sell your data and/or information details to any other organisation or individual.

Transfers may be made outside the EEA where we are satisfied that appropriate safeguards are in place over the transferring and processing of such information or data.

Storage of your personal data (including outside of the “EEA”)

The data and information that we collect, and process may be transferred to, and stored at, a destination outside of the UK. We will only do so on the basis that anyone to whom we transfer it to, protects it in the same way that we would and such entity or person or other third party is subject to the appropriate safeguards.

In the event that we transfer information to countries outside of the EEA, we will only do so where:

the European Commission has decided that the country or the organisation, entity or individual to whom we are transferring to or sharing your data and/or information with, will protect your information adequately;
the transfer has been authorised by the relevant data protection authority; and/or we have entered into a contract with the organisation, entity or individual with whom we are sharing your data and/or information (on such terms as approved by the European Commission), to ensure your information is adequately protected. If you wish to obtain a copy of the relevant data protection clauses in such contracts, please contact us at info@vdk.capital.

How we safeguard your information

We will take all steps reasonably necessary to ensure that your information and/or data is treated securely and in accordance with this Privacy Policy.

We have extensive controls in place to maintain the security of our information and information systems. The information that we handle is protected with safeguards appropriate to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where personal information is gathered, processed or stored is limited to authorised employees. As a condition of employment, VDK Capital’s employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive personal data is limited to those employees who need to it to perform their roles. Unauthorised use or disclosure of confidential client information by an employee is prohibited and may result in disciplinary measures.

Your Rights

In all the above cases in which we collect, use or store your personal data, you may have the following rights and, in most cases, you can exercise them free of charge. These rights include:

The right to obtain information regarding the processing of your Personal Data and access to the personal data which we hold about you;
The right to withdraw your consent to the processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, we may need to retain personal data to comply with a legal obligation;
In some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided directly to VDK Capital;
The right to request that we rectify your personal data if it is inaccurate or incomplete;
The right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
The right to object to, or request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to refuse that request; and
The right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us. You can exercise your rights by contacting us using the details listed below.

Questions and Concerns

If you have any questions or concerns about VDK Capital’s processing of your personal data, or about this Policy, please contact us at info@vdk.capital. If you are not satisfied with the response you receive, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, we will provide you with the contact information for that regulator.

How long we keep your information

How long we will hold your personal data for will vary and will be determined by the following criteria:

The purpose for which we are using it – VDK Capital will need to keep the data for as long as is necessary for that purpose; and
Legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

We may, on exception, retain your information for longer periods, particularly where we need to withhold destruction or disposal based on an order from the any courts of competent authority, or in relation to an investigation by law enforcement agencies or our regulators. This is intended to make sure that we are able to produce records as evidence, if needed to those respective authorities. If you would like more information about how long we keep your information, please contact us at info@vdk.capital.

Last updated: October [20] 2020