1. Introduction and Purpose
1.1. The General Data Protection Regulation (“GDPR”) in the EU and the Data Protection Act 2018 (“DPA”) in the UK governs the controlling and processing, such as the use or holding, of personal data, which is essentially any information about identifiable living individuals, and also gives those individuals certain rights and remedies in respect of that information.
1.2. The purpose of this notice is to supply you with the required information at the time of providing us with your personal data. This will lay out the essentials such as the what; where; when; and how in relation to the personal information collected. This should help you feel more confident about the privacy and the security of your personal information.
2. Identity and contact details of the Data Controller
2.1. Variety Capital Limited, company registration (12242771), with its registered office at Office 7 35 - 37 Ludgate Hill, London, England, EC4M 7JN, is the Data Controller and is committed to protecting the rights of individuals in line with the GDPR/DPA.
2.2. If you have any questions with respect to how Variety Capital Limited controls and processes personal data, please contact us at firstname.lastname@example.org.
3. When do we collect information?
3.1. We will collect information from you when you visit and/or use our website (https://www.varietycapital.co.uk), when we provide products or services to you or our client, when you contact us in person, by telephone, by email or by post and/or when performing any other activities that form part of our business. We also collect information from you when you provide feedback or complete a contact form on our website.
4. What information will we collect and why?
4.1. We typically collect or obtain your personal information because you give it to us (for example, in a form on our website). In some cases, we will also collect personal information about you indirectly from third parties such as: (i) your employer where we provide it with products or services; (ii) third parties such as providers of “know your client” and anti-money laundering services which we sometimes use to help us meet our legal requirements in this area and to help us verify your identity where we provide you or your employer with products or services; (iii) intermediaries (such as independent financial advisers and wealth managers); (iv) background check providers which we sometimes use to verify your identity when you apply for a job through our website; (v) third party service providers that help us to operate our website; and (vi) from publicly available sources such as business and employment oriented social networking services and jobs boards.
4.2. We may collect the following information depending on the services, activities or products that we provide or undertake:
your contact details, such as your name, address, telephone number and email address;
your date of birth, nationality, country of birth, country of residence, employment status and tax identification number (i.e. National Insurance Number);
passport details, driving licence and utility bills; details of your employment status, income and source of wealth and tax residency;
details of how you use any product or service provided by Variety Capital Limited;
postings on any blogs, forums, wikis, and any other social media applications and services that we provide;
IP address; browser and device type; username that is used by you for one of our products or services;
language; access times and duration; details of how you like to use our website or the interactive products, tools, other technology or services we provide to you or our clients; and
websites that you visited before and after visiting our website; details of how you like to interact with us, and similar information.
In some cases, you are not obliged to provide any personal data to us, but if you have requested information or a service from us, we may not be able to provide it without certain information, such as your contact details. Before we can begin providing you with certain services, we need to obtain certain information about you, so that we can verify your identity in order for us to meet our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 and any other applicable legislation and for the purposes of crime prevention and fraud prevention. You are obliged to provide this information and if you do not provide it, we will be unable to provide you with requested information or services.
5. Cookies Policy
5.2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
5.3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
5.4. Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website.
5.5. We use session and persistent cookies on our website.
5.6. The names of the cookies that we use on our website, and the purposes for which they are used, are set out below:
Cookie Name Purpose Duration Cookie Type
XSRF-TOKEN Used for security reasons Session Essential
hs Used for security reasons Session Essential
svSession Used in connection with user login 2 years Essential
SSR-caching Used to indicate the system from which the site was rendered 1 minute Essential
_wixCIDX Used for system monitoring/debugging 3 months Essential
_wix_browser_sess Used for system monitoring/debugging Session Essential
consent-policy Used for cookie banner parameters 12 months Essential
smSession Used to identify logged in site members Session Essential
TS* Used for security and anti-fraud reasons Session Essential
bSession Used for system effectiveness measurement 30 minutes Essential
fedops.logger.sessionId Used for stability/effectiveness measurement 12 months Essential
wixLanguage Used on multilingual websites to save user language preference 12 months Functional
5.7 You can delete cookies already stored on your computer; for example:
in Internet Explorer (version 11), you must manually delete cookie files (you can find instructions for doing so at: HTTP://WINDOWS.MICROSOFT.COM/EN-GB/INTERNET-EXPLORER/DELETE-MANAGE-COOKIES#IE=IE-11); in Firefox (version 47), you can delete cookies by clicking “Tools”, “Options” and “Privacy”, then selecting “Use custom settings for history” from the drop-down menu, clicking “Show Cookies”, and then clicking “Remove All Cookies”; and in Chrome (version 52), you can delete all cookies by accessing the “Customise and control” menu, and clicking “Settings”, “Show advanced settings” and “Clear browsing data”, and then selecting “Cookies and other site and plug-in data” before clicking “Clear browsing data”.
5.8 Deleting cookies will have a negative impact on the usability of many websites.
6. Automated Processing
6.1. Variety Capital Limited does not make use of automated processing or decision making.
7. How will we use your information?
7.1. We use information held by you in the following ways:
to process your application to use our services;
to undertake checks such as identification verification checks with fraud prevention agencies to enable us to comply with our anti-money laundering obligations and for the purposes of crime prevention and fraud prevention;
to comply with our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
to help protect your information and prevent unauthorised access to it;
to deal with any queries, complaints or problems reported by you;
to generate statistics relating to use of our website, such as the popularity of certain features or services. We do not use personally identifiable information for these purposes;
if required to do so by law and to the extent necessary for the proper operation of our systems, to protect us/our customers, or for the enforcement of any agreement between you and us;
to comply with applicable legal or regulatory requirements;
in relation to requests and communications from public or judicial authorities with the necessary authorisation;
in relation to financial accounting, invoicing and risk analysis purposes; in relation to prudent operational management (including credit and risk management, insurance, audit, training and similar administrative purposes);
in relation to services we receive from our professional advisors, such as lawyers, accountants and consultants;
in connection with arrangements we have in place with intermediaries, brokers and other individuals and entities that partner with us;
for client relationship purposes, which involve: (i) sending you Variety Capital Limited thought leadership or details of Variety Capital Limited products and services that we think might be of interest to you or your employer; (ii) contacting you to receive feedback on Variety Capital Limited products or services; and (iii) contacting you for other marketing or research purposes;
to notify you of changes to our services and products; to manage and help improve the services we provide to you;
to manage and improve our website (including by drawing up statistics on the usage of our website);
to tailor content of our website to provide you with a more personalised experience and draw your attention to information about products and services that may be of interest to you;
to manage and respond to any request that you submit through our website;
to help us learn more about you, the products and services that you or your employer receive from Variety Capital Limited, and other products and services that you or your employer might be interested in receiving; and
to correspond with you in relation to services you use on our website or information you provide via our website. This correspondence is usually with you, our service providers, or public or judicial authorities with the necessary authorisation.
8. Variety Capital Limited will only use your personal information on the following legal grounds:
Providing our contracts & services to you: We’ll process your personal information to carry out our responsibilities resulting from any commercial agreements or contracts you’ve entered into with us and to provide you with the information, products and services you’ve asked from us, which may include online services.
Complying with applicable laws: We may process your personal information to comply with any legal obligation we’re subject to.
carry out market research and product development; provide you with business-to-business marketing information about our services or products. You may object to this type of marketing at any time by emailing or telephoning us using the Contact section of our website; develop and test the effectiveness of marketing activities; develop, test and manage our brand, products and services; study and also manage how our professional business clients use products and services from us and our business partners; and manage risk for us and our clients.
This requires us to carry out an assessment of our interests in using your personal data against the interests you have as a citizen and the rights you have under data protection laws.
Consent: We may process your personal information for different purposes where you’ve provided your consent to do so (e.g. collecting your preferences when we plan and host conferences and seminars).
YOU MAY OPT OUT OF RECEIVING THIS INFORMATION WHEN WE COLLECT DETAILS OR AT ANY TIME BY CONTACTING US AT: email@example.com
9. How will we protect your information?
9.1. We take appropriate security measures (including physical, electronic and procedural measures) to help protect the confidentiality, integrity and availability of your personal information from unauthorised access and disclosure.
10. Who would we disclose your information to?
10.1. We may disclose your information to:
businesses that are legally part of the same group of companies within Variety Capital Limited, or that become part of that group;
our brokers, dealers, IT providers, services providers and agents in order to provide and maintain the provision of the services;
professional advisors and third parties that provide services to us such as such as financial advisors and platform providers, providers of marketing services, auditors, accountants, lawyers and other professional advisers (e.g. compliance consultants and HR consultants and recruitment advisors), to the extent that they require access to the information in order to advise us or provide services to us;
auditors appointed by such professional advisors or third party service providers;
fraud prevention agencies and other organisations to allow us to undertake the checks set out below. We will supply details of such agencies on request;
the Financial Conduct Authority, Central Bank of Ireland, or any relevant regulatory authority or stock exchange where they are entitled to require disclosure in connection with our business activities;
meet applicable law, the order of a court or market rules and codes of practice applicable to the circumstances at the time;
investigate or prevent fraud or activities believed to be illegal or otherwise in breach of applicable law;
relevant tax, payments and customs authority, who may pass this on to tax authorities in other jurisdictions. The is tax regulations require us to collect information about each investor’s tax residency; and prospective sellers or buyers of the “Variety Capital” business or assets in the event that we sell or buy any business or assets, in which case we will disclose your personal information. If all of Variety Capital Limited’s assets are acquired by a third party, in which case personal information held by it about its clients may be one of the transferred assets.
11. We will not lend or sell your information to third parties.
12. Data retention
12.1. We will hold your personal information on Variety Capital Limited’s systems for as long as is necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory requirements.
13. Transferring information overseas
13.1. We may share your personal information with our service providers, regulatory bodies and financial counterparties and this may involve transferring it to countries outside the European Economic Area (EEA) whose data protection laws may not be as extensive as those which apply to us. Where we do so, we will ensure that we do this in accordance with the Acts and take appropriate measures to ensure that the level of protection which applies to your personal information processed in these countries is similar to that which applies within the EEA. Such measures may include only transferring your data to jurisdictions in respect of which there is a European Commission adequacy decision or, where this is not the case, by using model clauses which have been approved by the European Commission.
14. Your rights
14.1. You have a key right to learn and have access to what personal information is held and undergoing processing by Variety Capital Limited and able to ask us for details on this.
14.2. When we receive such a request we will endeavour to provide you with these details without delay and at the latest within one month of receipt. We may extend the period of compliance by a further two months where requests are complex or numerous. In such instances Variety Capital Limited will inform you within one month of the receipt of the request and explain why the extension is necessary.
14.3. When Variety Capital Limited receives a subject access request we will provide a copy of the information held free of charge. Variety Capital Limited may charge a reasonable fee to comply with requests for further copies of the same information. This does not mean that we will charge for all subsequent access requests rather that the Variety Capital Limited reserves the right to charge a fee based on the administrative cost of providing the information.
14.4. If the after reviewing a request we believe the request is manifestly unfounded or excessive, particularly if it is repetitive, then Variety Capital Limited may charge a ‘reasonable fee’ which will be decided on a case by case basis. In certain circumstances Variety Capital Limited may even refuse to respond to such requests.
14.5. You also have the following rights (unless exemptions apply), which can be exercised by contacting us using the details provided below.
14.6. The right:
to ask us not to process your personal data for marketing purposes;
to prevent any processing of personal data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
to request the rectification or completion of personal data which are inaccurate or incomplete; to restrict or object to the processing of your personal data;
to request its erasure under certain circumstances; in certain circumstances, to receive your personal data, which you have provided to us, in a structured, commonly-used and machine-readable format and the right to transmit that data to another data controller without hindrance, or to have that personal data transmitted to another data controller, where technically feasible (from 25th May 2018 onwards);
to be informed about any use of your personal data to make automated decisions about you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
to lodge a complaint about the way in which your personal data is being used to your Data Protection Authority or our supervisory authority: The Information Commissioner’s Office (United Kingdom)
14.7. When you contact us to exercise any of the rights above, we may ask you to provide some additional information in order to verify your identity, such as your name, your address and proof of identity.
14.8. If you would like to lodge a complaint or exercise any of your rights set out above, you can contact us at firstname.lastname@example.org