Vision & Beyond Capital Investments and its subsidiaries and affiliates (collectively “V&B”) are determined and committed to implementing measures to protect Personal Information (“PI”) and processing PI in accordance with applicable privacy and data protection laws.

 

V&B’s privacy notices set out the PI it collects, the purposes for which PI is collected and processed, who it may be disclosed to as well as your rights. For further information please click on the notice that is relevant to your relationship with V&B. In addition, our Cookie Notice applies to any person visiting V&B’s website.

 

Introduction

V&B is committed to processing PI, including sensitive personal information (“SPI”), in line with all applicable privacy and data protection laws.  References to “you” or “your” refers to individuals whose PI is processed by V&B, including clients with direct or indirect relationships (for example, clients who invest through an intermediary); employees, contingent workers, officers, agents (together “Representatives”); and beneficial owners of an organization or entity in connection with:

• Services provided to potential and actual clients;

• Transactions in which V&B is a party, including those which V&B takes part in on behalf of clients; or

• Services that are provided to V&B by a third-party.

This Privacy Notice sets out the purposes for which V&B collects, uses and/or discloses (collectively “processing”) PI and how it is protected. It also states your rights in connection with the processing of PI.

Additional terms and conditions governing how V&B collects, uses and/or discloses PI, which must be read in conjunction with this Privacy Notice.

 

PI that V&B collects 

PI is information regarding a person, which can be used in isolation or in combination with other sources to identify that person; however, it does not include information where the identity of the person or the specific detail of the information has been removed and, as a result, is anonymous. SPI, a sub-category of PI, includes but is not limited to PI concerning race or ethnicity, religious or philosophical beliefs, sex, sexual orientation, political leanings or opinions, membership in trade unions, health and genetic information, and biometric data.

The information that V&B collects will depend on the services provided and V&B’s relationship with you. Following is an explanation of how V&B categorizes PI that it processes (these provide examples but are not exhaustive):

• Identification information

Name, title, gender, marital status, date of birth, passport number, driver’s license number, identification numbers, signature;

• Contact information

Address, telephone number, email address, social media profiles;

• Electronic Monitoring information

To the extent permitted by law, we may record and monitor your electronic communications with us;

• Financial information

Bank account and credit card numbers;

• Marketing and communications information

Preferences and data relating to whether marketing communications from V&B have been viewed;

• Professional information

Job title, position, work addresses, telephone numbers, email addresses;

• Profile information

Username / password for online services that you have access to, investments, services that have been requested or inquired about, communications responded to, and survey responses;

• Services information

Payment details, information concerning services provided to V&B by you and vice versa;

• Building and Assets Security information

Records concerning in-person visits, including recordings;

• Technical information

Use of and interaction with online services, IP addresses, browser information, plug in types and versions, and operating systems

• SPI

Where allowed by law, V&B may collect information about criminal convictions and offenses, when legally required, disability so that reasonable accommodations can be made, sexual orientation if details concerning a spouse or partner are shared, and political affiliations.

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Following is a non-exhaustive list of ways in which V&B collects PI:

• When it is provided to V&B in connection with a product or service;

• When you represent an organization or entity that is a client or vendor of V&B and the client or vendor provides your PI;

• When you provide PI during the course of your relationship with V&B, including when the details of your PI and/or the services V&B provides change;

• When you choose to make PI public, including through social media;

• When PI is provided by third parties;

• When you visit V&B’s website or use V&B’s online services.

Subject to applicable law, V&B may also create and store records of your interactions with V&B.

Unless we otherwise indicate that the provision of specific PI is optional, any PI we request is necessary for us to provide you or your organization or entity with the products and services requested. If you do not provide the PI requested, we may not be able to provide those products and services.

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Purpose and legal basis for processing your PI

Following is a non-exhaustive list of reasonable purposes for which V&B processes PI:

• Deciding whether or not to enter into a business relationship with you, including the performance of due diligence;

• Delivering services you have requested and providing access to V&B’s services;

• Managing payments, fees and charges and collecting money owed to V&B;

• Managing V&B’s relationship with you and notifying you about any changes to the terms of such relationship;

• Interacting with governmental or regulatory entities or other authorities;

• Detecting and/or preventing fraud and other criminal activity and to protect V&B’s assets and personnel;

• Managing and protecting V&B’s business, including improving security, troubleshooting data and systems, system maintenance and testing, data hosting, and managing our offices and facilities;

• Promoting client services, including notifying you about services that V&B offers or provides;

• Providing you with marketing communications and updates.
   

To whom V&B discloses PI

In connection with one or more of the purposes identified above, V&B may disclose PI in any jurisdiction to:

• V&B affiliates, subsidiaries, management, and employees;

• Professional advisors that provide services to V&B, including but not limited to IT systems providers, platform providers, financial advisors, brokers, consultants, accountants, and lawyers;

• Providers of goods and services, including marketing services to whom V&B is permitted to disclose your PI, intermediaries, brokers, and other individuals and entities that partner with V&B;

• Authorities, including but not limited to national and international regulatory or enforcement bodies, agencies, courts or other tribunals or tax authorities, or their agents in instances where V&B is required or permitted to do so under applicable laws or regulations;

• Potential buyers, transferees, partners or sellers (and their advisers) with respect to an actual or potential transfer or merger of or with all or part of V&B’s business, assets, or associated rights or interests;

• Agencies or organizations that assist with due diligence efforts, including those that provide anti-money laundering and anti-terrorism financing research in order to detect fraud and other potential criminal activity; or

• Individuals to whom disclosure is permitted or required by local or foreign law, regulation or any other applicable document.
   

International transfers

V&B may transfer PI to a location outside of the country where you reside or where services are provided. Although the country to which PI may be transferred may not have the same level of privacy and data protection laws, V&B ensures the same level of security and controls to the processing of PI wherever it is processed. V&B requires that any third-party service providers processing PI on V&B’s behalf comply with V&B’s policies and procedures for processing PI.

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Marketing and opt-out rights

If you notify V&B that you do not want to receive marketing materials, V&B will not process your PI for marketing purposes. You can request that V&B stop processing your PI for marketing purposes at any time by clicking on opt-out links in the electronic marketing materials we send you, by making a request to V&B personnel, or by using the details set out in the “Contacting Us” section of this privacy notice.

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Third-party marketing/sale of PI

V&B will not share, sell or disclose your PI to third parties for their own marketing purposes.

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PI retention

V&B will process your PI for only as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory, accounting, reporting, internal policy requirements or for the establishment or defense of legal claims.

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PI security

We use an array of measures to ensure a level of security in PI processing, including:

• Education and training of relevant staff;

• Ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;

• Implementing systems to restore access to PI in a timely manner in the event of a physical or technical issue;

• Controls to restrict access to PI;

• Technological security tools, including fire walls, encryption (industry standard SSL encryption with 128-bit key lengths), and anti-virus software;

• Physical security tools, including building access controls;

• External technical assessments, security audits and vendor due diligence;

• Segregation of networks;

• Application and end-point security;

• Real-time monitoring of data leakage controls;

• Cybersecurity defenses; and

• Incident reporting and management.

In spite of its security measures, including those listed above, V&B cannot guarantee the security of data and information transmitted over the internet and/or by electronic mail, which always includes the risk of access and interception. You should never send any PI by open or unsecure means via the internet. V&B is committed to protecting personal information but cannot guarantee the security of data transmitted to or by V&B.

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Your rights

In certain circumstances you may have the following rights in relation to the processing of your PI:

• To request a copy of any of your PI that V&B processes and to seek information concerning how V&B uses and shares your PI;

• To object to the processing of your PI if your PI is being processed on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling) or for direct marketing purposes;

• To request that V&B update or correct your PI that you believe is incorrect or incomplete;

• To request the deletion of your PI that you believe V&B does not have, or no longer has, a valid legal, regulatory or other reason or obligation to continue processing;

• To request that V&B restrict the way in which it processes your PI;

• To request a copy of your PI that has been provided to V&B in a commonly used electronic format.

The foregoing rights may be exercised at any time by contacting V&B. You will not be disadvantaged in any way by exercising your rights in relation to the processing of your PI.

To the extent permitted by applicable law or regulation, V&B reserves the right to charge an appropriate fee in connection with your exercise of the foregoing rights. 

V&B may need specific information from you to help confirm your identity and ensure your right to access the requested PI, or to exercise any other rights, which ensures that PI is not disclosed to any person who does not have the authority to receive it. We may also request additional reasonably necessary to process any request made by you with respect to your PI.

All legitimate requests will be responded to within a reasonable time period, or, if applicable, in accordance with applicable laws or regulations.

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Contacting V&B

Our legal representative is reachable via the following email address: legal@vnbinvest.com.