Vestrata values your privacy and cares about the way in which your personal information is treated.
1. WHAT TYPE OF INFORMATION WE COLLECT
We may collect personal information from you in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our services or as a result of your relationship with one or more of our staff and clients. The personal information that we process includes:
- basic information, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person
- contact information, such as your postal address, email address and phone number(s)
- financial information, such as payment-related information
- technical information, such as information from your visits to our website or applications or in relation to materials and communications we send to you electronically
- personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data
- any other information relating to you which you may provide to us.
2. HOW WE GET THE INFORMATION AND WHY WE HAVE IT
We collect information from you and about you and others as necessary in the course of providing our services.
We collect your personal information while monitoring our technology tools and services, including our websites and email communications sent to and from Vestrata.
We gather information about you when you provide it to us, or interact with us directly, for instance engaging with our staff or registering on our digital platform or applications.
We may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources.
We may collect or receive information about you from a range of third-party providers including, company registers, due diligence agencies and credit and fraud prevention agencies in order to comply with regulations and manage our reputational risk.
3. WHAT WE DO WITH PERSONAL INFORMATION
Vestrata collects and processes personal information about you in a number of ways, including through your use of our website and in the provision of services by us. We use that information:
- to provide and improve this website, including auditing and monitoring its use
- to provide and improve our services to you and to our clients, including handling the personal information of others on behalf of our clients
- to provide information requested by you
- to promote our services, including sending publications and details of events
- to manage and administer our relationship with you and our clients
- to fulfil our legal, regulatory and risk management obligations
- for the purposes of recruitment .
3.1 Use of Vestrata website
Facilities on our website may invite you to provide us with personal information such as for example our email queries facilities. The purpose of these facilities is apparent at the point that you provide your personal information and we only use that information for those purposes.
3.2 Marketing and other emails
We may also use a relationship management tool, where permitted by applicable local law, to assess the strength of the relationship between individuals in Vestrata and our clients or potential clients based on the frequency of email contact between them. We use that information in order to assess, analyse and improve the services that we provide.
3.3 Meetings, events and seminars
We will collect and process personal information about you in relation to your attendance at our offices or at an event or seminar organised by Vestrata or its business partners. We may share your information with IT and other service providers or business partners involved in organising or hosting the relevant event.
3.4 Other services
We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work. Please also see ‘Who we share your personal information with’ and ‘Which countries we transfer your personal information to’ below.
4. ON WHAT BASIS WE USE YOUR PERSONAL INFORMATION
We use your personal information on the following basis:
- to perform a contract, such as engaging with an individual to provide our services
- to comply with legal and regulatory obligations
- for legitimate business purposes. Please see ‘How we use your personal information’ for more detail.
5. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
Your personal information will be retained in accordance with our global data retention policy which categorises all of the information held by Vestrata and specifies the appropriate retention period for each category of data. Those periods are based on the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and Vestrata’s business purposes.
6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
We are an international company and any information that you provide to us may be shared with and processed by any entity in the worldwide network of Vestrata.
We may also share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:
- our professional advisers and auditors
- suppliers to whom we outsource certain services
- IT service providers to Vestrata
- third parties engaged in the course of the services we provide to clients and with their prior consent, such as technology service providers
- third parties involved in hosting or organising events or seminars
- regulatory authorities.
Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.
If in the future we re-organise or transfer all or part of our business, we may need to transfer your information to new Vestrata entities or to third parties through which the business of Vestrata will be carried out.
Vestrata does not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
7. HOW WE PROTECT YOUR PERSONAL INFORMATION
We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
8. WHICH COUNTRIES WE TRANSFER YOUR PERSONAL INFORMATION TO
The level of information protection in countries outside the EEA may be less than that offered within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. EU standard contractual clauses are in place between all Vestrata entities that share and process personal data. Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses.
9. YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
The European Union’s General Data Protection Regulation (https://eur-lex.europa.eu/eli/reg/2016/679/oj ) and other applicable data protection laws provide certain rights for data subjects. Should you wish to exercise any of the rights set out below please send your request to email@example.com.
9.1 Your rights of access and rectification
You are entitled to request details of the information we hold about you and how we process it. You may also have a right in accordance with applicable data protection law to have it rectified or deleted, to restrict our processing of that information, to stop un-authorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation. You may also have the right to lodge a complaint in relation to Vestrata’s processing of your personal information with a local supervisory authority.
9.2 Your rights to object to processing or to withdrawal
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above (see ‘How we use your personal information’) or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
We must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information by email.
10. DATA CONTROLLERS
There are different entities through which Vestrata provides its services. Depending on the location where our services are provided, another undertaking or entity in the Vestrata group may be the data controller in relation to your personal data.
11. HOW TO COMPLAIN
In the first instance you should direct any complaints or concerns you may have in relation to data protection to firstname.lastname@example.org. If you are not satisfied with our response you are entitled to complain to the competent national data protection agency in your jurisdiction.