Privacy Policy

Privacy Notice

CONTENTS

1. Important information and who we are

This Privacy Notice covers the Valloop Group of companies which includes Valloop Holdings Limited, Valloop Operations Limited, Valloop Limited, Valloop Deferred Consideration Securities Limited, Valloop Investment Management Limited, and Valloop Surety Limited services and products.

Valloop Operations Limited, Valloop Holdings Limited, Valloop Investment Management Limited, and Valloop Limited are all registered with the ICO in the UK.

The principles underpinning legislation are there to help us maintain transparency with our clients about how we process their personal data, only use it for legal or legitimate purposes, and make sure that usage is appropriate for that purpose. We do this as we want to be clear and transparent about the information we collect from you, how we use it, and how we store and protect it.

Valloop respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

As part of our business model, we are required to collect information of a personal nature from you in order for you to access our services. This information is used to operate the facilities we offer to you and to comply with laws and regulations.

This legislation provides individuals with new rights in relation to how your personal data is collected, used, and stored and provides new rules for organizations on how to handle personal data.

2. The data we collect about you

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 which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
  • Contact Data includes billing address, delivery address, email address, and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
  • Usage Data includes information about how you use our website, products, and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3. How is your personal data collected?

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

Direct interactions: You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

  • Apply for our products or services
  • Create an account on our website
  • Subscribe to our service or publications
  • Request marketing to be sent to you
  • Enter a competition, promotion, or survey
  • Give us feedback or contact us

Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from analytics providers such as Google based outside the EU.
  • Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services based inside or outside the EU.
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Click here to find out more about the types of lawful basis that we will rely on to process your personal data.

Purposes for which we will use your personal data:

  • We have set out below, in a table format, a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
  • We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the Table A above:

Internal Third Parties:

  • Other companies in the Valloop Group who provide services and act as joint controllers or processors and who are based in the UK and Luxembourg.

External Third Parties:

  • Service providers acting as processors based in the UK, EU, US, and other parts of the world who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the UK, EU, US, and other parts of the world who provide consultancy, banking, legal, insurance, and accounting services.
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Market researchers based in the UK, EU, US, and other parts of the world who provide research services.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We also have a data protection regime in place to oversee the effective and secure processing of your personal data. Details of these measures may be obtained from our data protection officer.

6. International transfers

We share your personal data within the Valloop Group. This will involve transferring your data outside the UK.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Where we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please email us at contact@valloop.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.

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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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We have also implemented measures to protect the integrity, availability, authenticity, and confidentiality of your data. We regularly test, assess, and evaluate the effectiveness of these measures to ensure the security of the processing.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfill the purposes 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 risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

For tax purposes, the law requires us to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for a minimum of six years after they cease being customers.

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

In some circumstances, we may anonymize 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

You can see more about these rights at any time by contacting us at contact@valloop.com.

If you wish to exercise any of the rights set out above, please contact us.

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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Valloop Group acting as joint controllers or processors and who are based in the United Kingdom, Gibraltar, and Jersey and provide IT and system administration services and undertake leadership reporting.

External Third Parties

  • Service providers acting as processors based in the United Kingdom and Gibraltar who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in the United Kingdom, Spain, France, and Gibraltar who provide consultancy, banking, legal, insurance, and accounting services.
  • HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom, who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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 processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data's accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    • We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 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.