GENERAL DISCLAIMER
All emails and attachments are confidential and for use by the addressee(s) only. If any message is received by anyone other than the intended addressee(s), it should not be read, copied or used but should be returned to the sender (by replying to the message) and then deleted from that person's system.
Confidentiality is not waived by mis-transmission. Internet e-mails are not necessarily secure. Verdigris does not accept responsibility for errors or omissions in the content of this email which arise as a result of transmission. Email messages and any attachments are provided for information purposes only and do not constitute an invitation or offer to buy or sell an investment. Any opinions expressed in an email message reflect the opinions of the individual sender and are subject to change without notice.
No legally binding commitments will be created by an e-mail message. Where Verdigris intends to create legally binding commitments these will be made through hard copy correspondence or documents.
An email could contain viruses when transmitted over the public networks. If you suspect that the e-mail may have been intercepted or amended, please contact the sender. You should virus-check attachments before opening.
PRIVACY POLICY
Our business is the provision of strategic advisory services. In the course of our interactions, we hold and process personal information. Verdigris respects the privacy of every individual whose personal information that it holds. We set out below important information about our processing of data relating to individuals by reference to the purposes for which we do so in the context of our business.
The "data controllers" (as defined in the Data Protection Legislation) in respect of your personal information will be Verdigris.
Information we collect
In order that we can provide our stakeholders with the services that meet their requirements and to comply with the legal requirements applicable to us, we may (to the extent relevant and appropriate) collect and hold information via telephone in writing, including email or otherwise.
What sort of Personal Data do we collect?
Professional contact details (including name, email address, phone number, facsimile numbers and mailing address)
Identification documentation (including photographic ID, date of birth and mailing address)
Financial details (including source of wealth, bank details and tax status)
Associated third party information (e.g. financial intermediary and beneficiaries of trusts)
How and why we use this information
The purposes for which we use the information are as follows, but depend upon individual circumstances:
Marketing to prospective stakeholders (where we may use the information provided to us to communicate directly via email and/or to provide information relating to our business)
Accepting stakeholders (where we may use and share the information with third parties to comply with our legal and regulatory obligations to know our clients and prevent money laundering, terrorism financing and other financial crimes)
Performing our services (where it is in the legitimate interests of our business to process personal information relating to other business contacts in order to provide services to our stakeholders – and may also be in the interests of the third party)
Operating our business (where we process personal data using a client relationship management system, local and wide area network and an internal/corporate system)
Verdigris’ employees use computer and communications equipment to access these systems, in order to perform their duties, and in particular work stations, laptop computers, other mobile computing devices and mobile phones. Personal data is stored on these devices appropriate to the use at the relevant time.
Who we share the information with
The legal basis on which we deal with people depends on the circumstances. In all cases we make sure that we have a legitimate reason to do so in connection with running and promoting our business.
We communicate and deal with a variety of persons from time to time in the ordinary course of our business, whether with vendors or acquirers of businesses or assets, advisers, managers of portfolio companies, suppliers, regulators or other competent authorities. In the course of doing so, having regard to the nature and purpose of those dealings, we will obtain and process personal data. We do not use the data for any purpose other than that for which it was given to us for no longer than necessary.
We may share information with certain third party organisations who perform certain tasks on our behalf. Information is only shared with these third parties to the extent necessary in order to enable them to provide the services required on our behalf. These third parties act on our instructions and are processors of the information. These organisations may:
provide IT or depositary/custody services to us;
provide credit reference services;
provide background checks;
provide AML and Sanctions screening services;
provide cloud hosting solutions;
other affiliates of Verdigris;
provide professional advice (such as accountancy, tax, legal and compliance advice); and
have a direct contractual relationship with a stakeholder. In these circumstances, the third party may also be a controller of the information for their own purposes. In these circumstances, we will seek to ensure that we have in place strong data sharing protocols with these third parties to govern and guide the sharing of information.
If you are involved in a transaction that Verdigris advises on or a potential transaction that Verdigris considers, we may store information relating to you. We collect and store this information for the purposes of:
assessing potential transactions;
maintaining records;
administering any transaction that we enter into;
assessing your suitability for involvement in a transaction, including by verifying your identity;
complying with legal obligations, including assessing and managing risk;
safeguarding our legal rights and interests;
seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
providing periodic business updates.
The personal information we hold about actual or potential management teams may be shared with:
companies who process personal information on Verdigris’ behalf, such as providers of cloud hosting solutions and other third-party outsourced services providers;
credit reference agencies;
financial intermediaries;
professional advisors, such as accountants, lawyers or other consultants;
other persons who have an interest or involvement in, or who are considering an involvement in a transaction; and
other affiliated entities.
In accordance with the Data Protection Laws, our legal basis for collecting and storing personal information about you is that such processing is necessary for our legitimate interests in running our business, in particular by considering potential investments, and administering transactions that we enter into. If we enter into a transaction that you are involved in, it will also be necessary for us to process your personal information for the purpose of performing that contract and to comply with our regulatory and legal obligations.
Cookies
We use small files which are stored on your hard drive by your browser (“cookies”) to monitor your use of this website during the time you access it. We do not collect personal data about you nor are these cookies used to create behavioural profiles of users or for advertising purposes.
This site uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics sets a number of cookies in order to evaluate your use of the site and compile reports for us on activity on the site.
if you wish to restrict or block the cookies which are set by our website, you can do this through your internet browser settings. Please visit www.allaboutcookies.org if you require instructions to do this.
How we protect information
Protecting the security and confidentiality of personal information is important to us.
All personal data which is collected and recorded, whether on paper or electronically, has appropriate safeguards in line with our legal obligations.
Our internal data protection policies and procedures are designed to minimise loss or damage.
Our information security controls are regularly reviewed to ensure they are aligned to industry standards and good practice. This provides a secure control environment that effectively manages risks to the confidentiality, integrity and availability of information. Additionally, our controls ensure we can restore data in situations where the data is corrupted or lost in a disaster recovery situation.
Where appropriate, we use encryption or other additional access restrictions or security measures to protect information. We also review our security procedures periodically to consider appropriate new technology and updated methods. But, despite our reasonable efforts, no security measure can ever be perfect or impenetrable.
Where the information is processed
Personal information is processed in the UK and European Economic Area (EEA). If and to the extent that personal information is being processed outside of the EEA, we will take additional steps to ensure that it is protected to at least an equivalent level as required by applicable data protection laws.
How long we keep the information
We have a legitimate interest to keep all records relating to our business for our internal purposes and to deal with queries or complaints which may arise.
Your rights
You have several rights under data protection law in relation to how Verdigris processes your information and may be entitled to access your personal data, request it is erased, restrict processing or request that any inaccurate personal data is rectified. Your rights are identified below. More information can be obtained from the Information Commissioner’s website at ico.org.uk.
Right to be informed
You have a right to receive clear and easy to understand information on what personal information we have, why and who we share it with. We do so by means of this Privacy Policy.
Right of access
You have the right to know what personal data we process and to be provided with access to the information. If you wish to receive a copy of the personal information, we hold on you, you may make a subject access request by writing to info@verdigristrategic.com.
Right to request erasure
You can ask for your information to be deleted or removed if there is not a compelling reason for Verdigris to retain it.
Right to restrict processing
You can ask to block or suppress the processing of your personal data for certain reasons. This means that we are still permitted to keep your information but only to ensure we don’t use it in the future for those reasons you have restricted.
Right to data portability
You can ask for a copy of your personal data for your own purposes to use across different services. In certain circumstances, you may move, copy or transfer the personal information we hold to another company in a safe and secure way; for example, if you were moving your pension to another pension provider.
Right to object or withdraw consent
You can object to Verdigris processing your personal data where it is based on our legitimate interests, in which case we can no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
You can object at any time to our use of personal data relating to you in connection with our direct marketing with a view attracting you as an investor. Where you do so, the personal data shall not afterwards be processed for such purposes.
Where we are processing personal data about you with your consent you can withdraw it at any time. However, where you do it may not be possible for us to continue to fulfil your instructions adequately or at all.
If you do not believe we have handled your information as set out in our Privacy Policy, or you otherwise wish to complain about our handling of data relating to you, please contact our Compliance Officer.
Changes to Privacy Policy
Verdigris may amend this Policy at any time, when we make any changes we’ll post the updated privacy policy on our website so that you’re always aware of what personal information we collect, how we use it and under what circumstances we disclose it. If you do not agree to any changes that we make you should not access the website or continue to access the website.