We will ensure that your Personal Information is handled in accordance with the law. The relevant law here is: (i) the UK Data Protection Act 2018, (ii) the EU General Data Protection Regulation, (iii) the Privacy and Electronic Communications (EC Directive) Regulations 2003 (iv) the French Data Protection Act and (v) all similar or related legislation relating to the processing of Personal Information and/or privacy applicable to Victoria PLC from time to time (together the “Data Protection Legislation”).
Victoria PLC collects personal information such as name, company (if appropriate), address (if appropriate) and e-mail address when you knowingly provide it to us. Our Web servers automatically collect statistical information about your visit such as pages visited and which browsers are used to visit our site.
USE OF PERSONAL INFORMATION
What sort of Personal Information do we collect?
When contacting us online, via telephone, in writing or otherwise you may provide Personal Information about yourself to us including your name and contact details (e.g. your address, email address and telephone number).
If you apply for or enquire about working for us (as an employee or in another capacity) we may also ask you to provide details such as your previous job title, your employment history, a copy of your CV and references and information relating to your right to work. We may also seek references and carry out checks with third parties if appropriate for the role you have applied for. This processing is justified either by our legitimate interests to carry out effective recruitment or it is necessary for us to comply with our legal obligations.
We sometimes ask members of our staff to provide details of their next of kin for the purpose of our emergency scenario planning or in case an incident occurs at work. We may also ask for details of their dependents, spouses and/or other people in relation to their employee benefits arrangements. We will only ever use this information for the benefit of our staff and only when justified by our legitimate interest to support our staff.
When we acquire a business, we will obtain some information about the employees and other staff who work in that business to carry out and improve our business in the pursuit of our legitimate interest.
If you provide services to us or have a business dealing with us (or are employed or engaged by an entity which provides services or has a business dealing with us), we may acquire your name, contact details, some employment information and we may acquire copies of ID documents or similar information, for the purpose of corresponding with you, carrying out and improving our business, analysing the use of our website and services in the pursuit of our legitimate interests. In certain situations, for example, if you are a director at a business, we are required under our legal obligations to conduct due diligence or carry out anti-money laundering processes.
How long do we keep your Personal Information?
We will only keep your Personal Information for as long as we reasonably require and, in any event, only for as long as the Data Protection Legislation and our own internal rules and policies allow.
YOUR RIGHTS AND DATA ACCURACY
You have certain rights in relation to your Personal Information – for example, the right to request that we erase your Personal Information (or part thereof) at any time, which request we will comply with unless we have a lawful reason to keep your information (for example, to comply with our legal obligations). Where relevant, we will also ensure that our group companies amend or erase your Personal Information (as applicable). Please contact us at the email address set out below if you wish to request any changes.
You also have the right, subject to certain exemptions, to: (a) see the Personal Information we hold about you and withdraw any consent you may have given to us; (b) to ask us to make any changes to ensure that any Personal Information we hold about you is accurate and up to date; and (c) in some cases communicate any information we hold about you to a specified third party. In certain jurisdictions, you have the right to provide instructions on the processing of personal data after your demise. If you wish to exercise any of these rights, please contact us at the email address set out below.
Please ensure that the Personal Information you provide via the website is accurate and complete and you notify us of any changes to your Personal Information as soon as possible so that we can update our records.
Whilst we will take all reasonable steps to protect your Personal Information, we cannot guarantee the security of any Personal Information you disclose online. You accept the inherent security implications of disclosing Personal Information online.
HOW AND WHY WE SHARE YOUR PERSONAL INFORMATION
Where it is necessary for the performance of our contract with you or for our internal business processes, we may share your Personal Information with certain third parties who reasonably need it in order to perform a function for you or provide a service to us – such as our group fund(s), the funds’ administrator, and our other group companies and our advisers. By submitting your Personal Information to us, you acknowledge that such third parties may receive and process your Personal Information. We will never sell your data.
In addition, it may be necessary to disclose your Personal Information if we are under a duty to disclose your Personal Information in order to comply with any legal obligation (such as anti-money laundering obligations), carry out an internal investigation, enforce any agreement we have with you or with a related party, or protect the rights, property, or safety of Victoria PLC, its group companies and/or our clients, directors, employees or other personnel. This includes exchanging information with other companies and organisations for the purposes of fraud protection and prevention.
MARKETING AND INDUSTRY UPDATES
Where you have expressly consented to receive from us or we otherwise have the right to send to you marketing materials, event invitations and/or industry updates we will use your Personal Information to do this (whether in hard copy or by email).
You can opt out of receiving these sorts of communications from us at any time by: (i) contacting us at the email address below, (ii) clicking the unsubscribe/”opt-out” button which are available in some of our emails or (iii) where the materials are sent by post, sending us a cancellation request to the address included in the materials.
LINKS TO OTHER SITES
From time to time, we may aggregate statistics, responses to any surveys and questionnaires, traffic patterns and related website information and disclose such aggregated data to third parties (such as Victoria PLC’s suppliers) for the purpose of Victoria PLC’s own marketing, advertising or other promotional purposes. Please note that any such aggregated data will not include any Personal Information and we will never make it available to third parties to use for their own marketing purposes.
To enable us to monitor and improve this website, we may gather and record on our servers certain aggregated data about you when you use it, including without limitation, the URL that you came from and go to and the parts of our website that you visit. Such aggregated data is primarily used to provide you with an enhanced on-line experience and will not include any Personal Information.
CONTACT US AND COMPLAINTS
You can opt out of receiving communications from us at any time by sending an e-mail to firstname.lastname@example.org or by contacting us at the following address: Worcester Road, Kidderminster, DY10 1JR.
If you have any questions or concerns about the way in which we have handled your Personal Information, please contact us at the email address above. Alternatively, you have the right to make a complaint to the Information Commissioner’s Office, the supervisory body in the UK, or to one of the competent European supervisory authorities: