Privacy Policy

Introduction

At Vuca Treasury, we are committed to protecting your privacy and maintaining the security of any personal information received from you. We strictly adhere to the requirements of the applicable data protection laws, including the General Data Protection Regulation and the UK Data Protection Act 2018.

The purpose of this statement is to explain to you what personal information Vuca Treasury Ltd and/or its affiliates (“Vuca Treasury”, “we”, “us” or “our”) collect, how we may use it and will look after it, as well as tell you about your privacy rights in relation to the processing of your personal data both in relation to our website but also when you use our services.

Third-party links

This website may include links to third-party 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Changes to the Privacy Statement and your duty to inform us of changes

This privacy statement is effective as of the 10th of February, 2020. As our business and applicable laws can change over time, so may the way we use and protect your personal data. As a result, we may need to make changes to this Privacy Notice. The most up to date Privacy Notice will always be published on our website and we will clearly identify the changes we have made in any updates. Continued use of the Website and communication with us will constitute your agreement to any such changes.

It is important that the personal data we hold about you is accurate and current. Please therefore keep us informed if your personal data changes (or if you wish to verify or remove your personal details) during your relationship with us by contacting us at info@vucatreasury.com.

The data we collect about you and how we collect it

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer the following types of personal data:

• Identity data: including first name, last name, marital status, title, date of birth and gender;
• Contact data: including residential address, email address and telephone number;
• Technical data: including IP address used to connect your computer or mobile device to the internet, browser type and version, operating system and platform and other technologies on the devices you use to access this Website.

We use different methods to collect personal data from you, including through:

• Direct interactions: For example, when we interact with you for business purposes or contact you with business related information that we consider may be of interest to you. Also, if you make an enquiry or submit a job application you will be asked to provide certain information including name, email address and telephone number.
• Automated technologies or interactions: When you interact with our Website, we may automatically collect information about your equipment, browsing action and patterns. This information is collected through cookies. A cookie is an element of data that our Website sends to your browser which is then stored on your system. You can set your browser to prevent this happening. Any information collected in this way can be used to identify you unless you change your browser settings.
• 3rd party or publicly available sources: For example, we may receive identity and contact data from publicly available sources like Companies House or public networking sites like LinkedIn and twitter.

“Sensitive data” refers to the various categories of personal data identified by data privacy laws as requiring special treatment. Such categories included racial or ethnic origin, political opinions, biometric and genetic data, criminal records, religious beliefs and physical and mental health. We do not collect sensitive data about you without your express consent and would only do so in accordance with data privacy laws.

How we use your personal data

We only use your personal data where required for specific purposes. Most commonly, we will use your personal data in the following circumstances:

• To perform the contract we are about to enter into or have entered into with you
• To contact you with business related information that we consider may be of interest to you;
• Where it is necessary for our legitimate interests (e.g. conducting our business in an efficient and compliant manner and the overall promotion of our business) and your interests and fundamental rights do not override those interests; and
• Where we need to comply with a legal or regulatory obligation

Unless we consider we have a legitimate business reason for contacting you, we will only contact you with your consent, and you have the right to withdraw your consent at any time.

We do not sell, rent or exchange your personal information with any third party for commercial reasons.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us. Our contact details are provided at the end of this policy.

The types of personal data we process

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you. The main categories of such data are as follows.

• Identity Data includes first name, middle names, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account details.
• Technical Data includes internet protocol (IP) address and other technology details on the devices you use to access this website.
• Marketing and Communications Data includes your preferences in receiving marketing from us.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless we have your explicit consent to do so. Please note that if you do fail to provide personal data we may not be able to perform the contract we have, or are entering into with you (for example, to provide you with services).

Sharing your personal data

We may share your personal data with the following.

• Our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers, software application providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the services and information you have requested or which we believe is of interest to you.
• Third parties where you have a relationship with that third party and you have consented to us sending information (for example other professional advisers, social media sites or other third-party application providers).
• Credit reference and fraud prevention agencies.
• Regulators to meet Vuca Treasury’s legal and regulatory obligations.
• Law enforcement agencies so that they may detect or prevent crime or prosecute offenders.
• Any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order).
• Any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts.
• Our professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities.
• Another organisation if we choose to sell, transfer or merge parts of our business or assets.
• Another organisation to whom we may transfer our letter of engagement with you or your employer/company or sub-contract some of the services we have agreed to carry out for you.
• Government departments where reporting is mandatory under applicable law.

We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties but this will not include information that can be used to identify you.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will retain your personal data for the duration of our business relationship and afterwards for as long as is necessary and relevant for our legitimate business purposes, in accordance with the relevant Vuca Treasury policies or as otherwise required by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).

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

In some circumstances we may 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.

Data Retention

We maintain a specific data retention policy to ensure that we only retain your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those through other means, and the applicable legal requirements.

International Transfers

We may from time to time wish to transfer personal data to our other group entities or third parties supporting the operation of our business which may involve transferring data outside the European Economic Area (EEA).

Prior to making any such transfer of personal data, we will take the necessary steps to ensure that a similar degree of protection is afforded to your personal data in accordance with the applicable data privacy laws.

Your legal rights

Under certain circumstances, by law, you have the following rights in relation to your personal data:

• Request access to your personal data (commonly known as “data subject access request”): this enables you to receive a copy of your personal data and to check that we are lawfully processing it;
• Request a correction to your personal data we hold about you: this entitles you to have any incomplete or inaccurate personal data corrected;
• Request the erasure of your personal data (often referred to as the “right to be forgotten”): this entitles you to request your personal data be deleted where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (below). Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request
• Object to the processing of your personal data: this entitles you to request that we no longer process your personal data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request the restriction of the processing of your personal data: this entitles you to request that we suspend the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interest but we need to hold some of it for the purpose of legal proceedings;
• Request transfer of your personal data: this entitles you to receive a copy of your personal data, or request we transmit such personal data to another party; and
• Withdraw your consent at any time: where we are relying on consent to process your personal data you may withdraw this consent at any time by contacting us at info@vucatreasury.com. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Contact us

Please do not hesitate to contact us, using the details below, if you:

• have any questions about privacy or this particular statement
• wish to exercise your rights in relation to your personal data rights
• wish to make a complaint about our use of your data

Email address: info@vucatreasury.com

Postal address: Vuca Treasury Ltd, 29 Farm Street, Mayfair, London, W1J 5RL

Telephone number: 0208 167 3850

If, despite our commitment and efforts to safeguard your personal data, you have any concerns or complaints about our privacy activities, you can contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact us in the first instance.