Privacy Policy

We respect your Privacy

VP Research, Inc (“VP”) collects, holds, uses, verifies and discloses (“processes”) information about individuals which may constitute personal data, under applicable data protection and privacy laws. Unless advised otherwise, all references to VP, “we”, or “our” in this Privacy Policy includes, individually and collectively, VP entities located in the United States and Europe that process personal data as controllers.

In connection with specific products or services offered by VP, you will also be provided with additional privacy policies or statements which are relevant to those specific products or services.

This Privacy Policy describes:

  • What personal data we collect;
  • How we collect your personal data;
  • What personal data is obtained from other sources;
  • The purposes for which we use your personal data;
  • The monitoring we do;
  • When we disclose your personal data;
  • How we protect your personal data;
  • How we retain your personal data;
  • What marketing we do;
  • Your rights under applicable law;
  • How we update this Privacy Policy; and
  • How you can contact us.

Please read this Privacy Policy carefully to understand how we process your personal data.

1. What personal data we collect?

If you deal with VP in your individual capacity (i.e. as an employee or prospective employee), then, depending on the jurisdiction you are in, we collect the following types of personal data about you:

  • Personal details, such as name, age, date of birth, gender, citizenship, occupation and marital status;
  • Contact details, such as current and previous address, telephone, email, in some cases both private and work related contact details;
  • Identification documents, such as your passport, copies which generally include a head and shoulders photograph from, as applicable, your passport, national identity card or driver’s license, as required and permitted by applicable laws and regulations addressing due diligence and related matters;
  • A government-issued personal identifier, such as depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number or Medicare Number etc. (as permitted by law); and
  • Personal details relating to your immediate family members and details relating to any senior political figures (e.g. senior military or government official) to whom you are connected.

If you deal with VP in the capacity of an officer, employee, director and or principal of a corporate or institutional clients, the personal data we collect about you personally includes:

  • Your name and contact details;
  • Your role/position/title and area of responsibility;

Of course, you are not required to supply any of the personal data that we request. However, failure to supply any of the personal data that we request may result in our being unable to open or maintain your account, provide services to you or your company, discuss any other opportunities with you or deal with other matters.

While we make every effort to ensure that all personal data we hold about you is accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal data. To the extent permissible under applicable law, we shall not be responsible for the authenticity of any personal data or sensitive personal data or any losses arising from any inaccurate or deficient personal data or sensitive personal data that you supply to us.

2. How do we collect your personal data?

The personal data we collect regarding you comes primarily from information that you submit to us or that is otherwise captured during the course of your relationship with us.

For clients, we obtain personal data about your officers or control persons from the forms and documents used when you apply for an account with us, from your transactions with us and from your access to or use of our products and services.

For employees or applicants for employment, we obtain personal data about you from your resume or job application form or other forms required for employment.

For individuals employed by a company providing service to VP, we request personal data about you from your employer.

We also collect personal data when we monitor or record our communications with you or through use of certain technology as detailed further below.

3. Personal data obtained from other sources

We also obtain your personal data from our agents or service providers acting on our behalf, from third parties authorized to provide us with such information, such as credit reporting bodies, other credit providers or other agencies used for running due diligence checks, authorized third parties performing identity verification procedures on our behalf and/or from third parties who provide services to you such as your financial adviser, financial planner, dealer group, accountant or other professional adviser.

The personal data we obtain through these sources may include personal details, contact details, identification documents, personal identifier, financial account information, and where permitted by applicable law and only to the extent needed information relating to trade union membership or criminal convictions. In addition, where VP is offering employment to you and these sources are performing identity verification functions in relation to such employment as part of a background check, they will disclose name, date of birth and address to a credit reporting agency if permitted by applicable law. In such instance, the credit reporting agency will perform an assessment of whether the information matches its record, either in whole or part, and provide the assessment results to us. Please inform VP using the contact information supplied below in the event you do not want your personal data verified against credit reporting agency information for identity verification purposes, and the firm will discuss other options available to you.

Some of this information is publicly accessible and/or reliable and independent databases that we access through an authorized third party to whom we disclose your personal data for the purpose of performing required identity verification procedures.

Where you are an individual associated with a corporation or institution with whom VP does business, your personal data will also be provided to us via that corporation or institution. Such personal data includes personal and contact details, financial information, identification documents and, where permitted by applicable law and only to the extent needed, information relating to political connections or criminal convictions.

4. What are the purposes and legal basis for which we use your personal data?

We are not allowed to process personal data if we do not have a valid legal ground. Accordingly, we, our associated firms and/or other persons acting on our or their behalf will only process and use your personal data:

(a) if necessary for our legitimate interests, (in each case provided such interests are not overridden by your privacy interests) or necessary for taking steps to enter into or executing a contract with you for the services or products you request, or for carrying out our obligations under such a contract, such as when we use your personal data including:

  • Administer and operate services in accordance with the customer documents (including without limitation authorizing or confirming transactions and for billing purposes);
  • To provide operational support and development of our businesses including to evaluate customer service, efficiency and cost, as well as risk management purposes;
  • To contact you about other services and products we offer (with your prior consent where required by applicable law);
  • For monitoring purposes specified section 5 below; and
  • For other legitimate interest as listed in (b) to (d) inclusive below.

(b) When dealing with us as an individual, where necessary for taking steps to enter into or executing a contract with you for employment; or for carrying out our obligations under such a contract or agreement, in this case, the provision of your personal data is a requirement necessary to enter into employment with us, meaning that you are obliged to provide your personal data to us in order to be employed by VP, including:

  • For recruitment purposes, to confirm your references and educational background and to consider your suitability for any current or future recruitment requirements;
  • In case of employees, to carry out the employment relationship, to fulfill our duties as an employer and to make use of our rights as employer; and
  • For internal training purposes.

(c) To exercise and defend our legal rights anywhere in the world including in relation to any litigation, disputes or contentious matter we or that of any VP affiliate anywhere in the world are involved in and/or to assist with investigations, complaints, regulatory requests, litigation, arbitration, mediation or requests from individuals;

(d) In order to comply with legal and regulatory obligations and requests, (including any legal or regulatory guidance, codes or opinions), applicable to us anywhere in the world or for the performance of a task carried out in the public interest, including:

  • To carry out credit, money laundering and conflict checks and for fraud, financial crime prevention purposes (and this may include consideration of information regarding political affiliations and criminal offences committed or alleged to have been committed); to verify your personal data we collect from you for such credit, money laundering and conflict checks;
  • For reporting (including without limitation transaction reporting) to, and audits by, national and international regulatory, enforcement or exchange bodies and complying with court orders associated with us; and for monitoring purposes specified below.

5. What monitoring do we conduct?

To the extent permitted by applicable law, we, our affiliates or any other persons on our or their behalf access, review, disclose, intercept, monitor and/or record (“Monitor”) (i) verbal and electronic messaging and communications (e.g., telephone, facsimile, sms, instant message, email, Bloomberg and any other electronic or recordable communications) with you and your agent (“Communications”) and (ii) your use of technology owned by or made accessible by us, our affiliates or any other persons on our or their behalf, including but not limited to systems that facilitate Communications with you or your agent, information processing, transmission, storage and access, as well as remote access (collectively “Systems”).

We will only Monitor Communications and Systems to the extent permissible under applicable law from time to time for the following purposes:

  1. to establish the existence of facts (e.g., keeping records of transactions);
  2. to ascertain compliance with regulatory or self-regulatory practices or procedures which relate to our business;
  3. to ascertain or demonstrate standards which are achieved or ought to be achieved by persons using Systems, including compliance with any terms of use associated with use of Communications and Systems;
  4. to prevent, detect or investigate crime, money laundering, fraud, financial crime and/or other breaches of applicable law;
  5. to comply with applicable laws and regulations, this Privacy Policy and any applicable policies and procedures;
  6. to safeguard against the loss, theft, unauthorized and unlawful collection, use, disclosure, destruction or other processing or misuse of confidential and proprietary information
  7. to prevent, detect or investigate unauthorized use of Communications and Systems and/or data (e.g., Monitoring to ensure compliance with the our policies and procedures, including without limitation those relating to information security and cyber security);
  8. to ensure the effective operation of VP’s Systems (including telephones, email and internet) systems;
  9. for security or health and safety purposes;
  10. for support and administration purposes;
  11. to assist with investigations, complaints, regulatory requests, litigation, arbitration, mediation or requests from individuals; or
  12. for evaluating the quality of customer service, efficiency, cost and risk management purposes.

Monitoring is conducted by us using various methods, including: (i) the use of “intelligent” automated monitoring tools; (ii) IT filtering tools which randomly review Communications and Systems; (iii) through random monitoring of Communications and Systems, e.g. by authorized supervisors randomly selecting certain electronic communications for review; (iv) specific monitoring of key Communications and Systems e.g. in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (v) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or (vi) using other similar Monitoring technology that may become available from time to time.

We also use cookies and similar technologies to collect information about you when you visit our websites or interact with us on-line e.g. via email or other electronic means. To find out more about how we use cookies and similar technologies, how we process the information obtained through cookies and how to reject cookies, see Our Global Cookies Policy at www.variantperception.com/cookie-policy

6. When do we disclose personal data we collect about you?

You should know that:

  • VP does not sell, rent or trade your personal data; and
  • VP does not disclose your personal data, except as described in this Privacy Policy.

Our processing and use of your personal data, for the purposes specified in this Privacy Policy, includes disclosure of your personal data:

  • Between us and our affiliates, a list of which may be referred to in the corporate website of VP.
  • To other persons processing your personal data on our behalf or otherwise providing us or them with professional or other services including our associated firms and vendors which conduct operational, technology and customer service functions in various jurisdictions;
  • To third parties such as settlement agents, overseas banks or exchange or clearing houses to whom we disclose personal data in the course of providing products and services to you;
  • To credit reference, fraud prevention and other similar agencies, and other financial institutions, with whom information is shared for credit and money laundering checking and fraud prevention purposes;
  • To persons to whom we assign or novate our rights or obligations;
  • To a prospective seller or buyer in the event that we sell or buy any business or assets or if all or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
  • To national and international regulatory, enforcement or exchange bodies or courts anywhere in the world as required by applicable law or regulations anywhere in the world or at their request; and
  • To any third party to whom you authorize us to disclose your personal data.

These disclosures may involve overseas storage and other overseas transfer, processing and use of your personal data, and disclosure to these third parties, including in or to countries or territories where the laws may provide a different level of data protection. Without limiting the foregoing, your data will be disclosed by us to our affiliates and vendors which conduct operational, technology and customer service functions in various jurisdictions including the United Kingdom and the United States of America and other countries where VP operates. When personal data is transferred to such countries or territories not recognized under applicable law as offering an adequate level of data protection, we have put in place appropriate data transfer mechanisms as required under applicable law to ensure personal data remains protected. You can obtain a copy of the relevant data transfer mechanism we have put in place to protect personal data by contacting our Data Protection Office as described below.

7. How do we protect your personal data we collect about you?

VP maintains appropriate physical, technical and procedural safeguards designed to protect any information that you provide to us from accidental or unauthorized loss, misuse, damage, modification, access or disclosure.

VP has established information security procedures and processes designed to:

  • Safeguard the confidentiality and privacy of information resources;
  • Properly classify information resources;
  • Meet legal and regulatory obligations concerning the protection of information resources;
  • Implement and maintain information security policies and procedures;
  • Integrate protection of information resources into the process lifecycles of the business;
  • Educate those working for or on behalf of VP on Information Security policies and responsibilities; and
  • Authenticate users and limit access to information resources based on authorization that has been granted.

Third parties who process your personal data on our behalf are required to adhere to appropriate security standards designed to protect such information against unauthorized access, destruction or loss.

8. How do we retain your personal data?

We retain personal data in an identifiable form in accordance with our records retention policy which establishes general standards and procedures regarding the retention, handling and disposition of personal data. Personal data is retained as long as necessary to meet legal, regulatory and business requirements. Retention periods will be extended if we are required to preserve personal data in connection with litigation, investigations and proceedings. Upon request, we and/or our affiliates will provide you with more information on the exact retention periods applying to Your Information in each case.

9. What marketing do we conduct?

If there are any products or services that we or our affiliates believe may be of particular interest to you, whether provided by us, by our affiliates, we or our affiliates will contact you by mail, email, telephone, etc., including outside standard working hours or if you are traveling overseas. Where required by applicable law, we will request your prior consent before we or our affiliates use your personal data for marketing purposes. If you do not wish us to use or provide to our affiliates Your Information for marketing purposes, you may notify us atdataprotectionofficer@variantperception.com

any time or as directed in any marketing materials we send to you from time to time. Please note that if you do not wish us or our affiliates to contact you for such purposes, we or our affiliates may need to limit the range of products and services which we or our affiliates will offer to you or we or our affiliates may not be able to open an account for you or continue our relationship with you.

10. What rights do you have?

To the extent provided by applicable law and subject to exemptions thereunder, you have the right to request access to and rectification or erasure of personal data; to obtain restriction of the processing of personal data; to object to the processing of personal data (including direct marketing); and to data portability. If we have collected personal data with your consent, please note that you have the right to withdraw this consent at any time, subject to applicable law and exemptions thereunder. If you wish to exercise any of your data protection rights or if you consider that we have processed personal data in violation of applicable law, please contact our Data Protection Office at described below. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal data. We will process your request within the time provided by applicable law. If you consider that we have processed personal data in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you may also lodge a complaint with a competent data protection authority.

In the case of a request for access to personal data, we reserve the right to charge an appropriate fee, if applicable and where permitted under applicable law. If a fee is chargeable we will advise you of the likely fee in advance where required under applicable law.

11. How do we update this Privacy Policy?

We may change or update portions of this Privacy Policy to reflect changes in our practices and or applicable law and regulation. Please check this Privacy Policy from time to time so you are aware of any changes or updates to the Privacy Policy, which may be indicated by a change in the effective date noted at the beginning of the Privacy Policy. Where required under applicable data protection and privacy laws, we will notify you of any change or update portions of this Privacy Policy by individual message or by disclosing the changes to the data processing on a publicly available medium.

12. How can you Contact Us?

If you would like to contact us in respect of any element of this Privacy Policy, including, without limitation and subject to applicable data protection law, where you wish to exercise any of your data protection rights or where you wish to raise a complaint or grievance please contact our Data Protection Office on the details below.

If you make a complaint about a breach of applicable data protection laws by VP, VP will respond as soon as possible to let you know who is responsible for managing your complaint. VP will investigate the complaint and where necessary we will consult with third parties who may be involved in the processing of your personal data. VP will respond to all complaints within such timeframes required under applicable law. If further investigation is required, it will be carried out and then you will be notified of a proposed remedy. This will be confirmed to you in writing.

If you do not receive a response from us within such timeframes required under applicable law or your complaint is not resolved within that time to your satisfaction, you may apply to the applicable data protection authorities to have your complaint heard and determined.

We will investigate any complaint and will notify you of the making of a decision in relation to your complaint as soon as is practicable after it has been made.

Contact Details:

By email:

dataprotectionofficer@variantperception.com

By post:

Data Protection Officer

VP Research, Inc

6836 Carnegie Blvd. Suite 240

Charlotte, NC 28211 USA