Collection and creation of data
We may collect, obtain, or create personal data about you from the following sources:
Data you provide: we may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means, or if you provide us with your business card);
Relationship data: we may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., in the course of corresponding with you);
Data you make public: we may collect or obtain your Personal Data that you choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post);
Website data: we may collect or obtain your Personal Data when you visit our website or use any features or resources available on or through our website;
Third party information: we may collect or obtain your Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.); and
Data creation: we may create Personal Data about you, such as records of your communications and interactions with us, including attendance at events we hold or interviews in the course of applying for a job with us. We may record telephone calls, meetings, depositions, and other interactions in which you are involved, in accordance with applicable law.
Categories of personal data we may process
We may process the following categories of personal data about you:
Personal details: given name(s); preferred name; and photograph;
Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences;
Identifier information: passport or national identity number;
Contact details: correspondence address; telephone number; email address; and details of your public social media profile(s).
Matter details: details of individuals interacting with us; Personal Data included in correspondence, transaction documents, evidence or other materials that we process in the course of analyzing investment opportunities and manage investments;
Attendance records: details of meetings and other events organised by or on behalf of Vektor Partners that you have attended;
Consent records: records of any consents you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent);
Data relating to our website: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to our website; and
Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
Sensitive personal data
We may have to process your sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your sensitive Personal Data for any reason, we rely on one of the following legal bases:
Compliance with applicable law: we may process your sensitive Personal Data where the processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
Detection and prevention of crime: we may process your sensitive Personal Data where the processing is necessary for the detection or prevention of crime (including the prevention of fraud);
Establishment, exercise or defence of legal rights: we may process your pensitive Personal Data where the processing is necessary for the establishment, exercise or defence of legal rights; or
Consent: we may process your sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to processing your sensitive Personal Data (this legal basis is not used in relation to processing that we are legally required to carry out).
Disclosure of personal data to third parties
We may disclose your Personal Data for legitimate business purposes (including operating our website and investigating investment opportunities with you), in accordance with applicable law and subject to applicable professional and regulatory requirements regarding confidentiality and professional secrecy. In addition, we may disclose your Personal Data to:
Legal and regulatory authorities: upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
Accountants, auditors, lawyers and other outside professional advisors to Vektor Partners: subject to binding contractual obligations of confidentiality;
Third party processors (such as providers of data hosting services and document review services): located anywhere in the world, subject to the requirements noted below in this Section 6;
Any relevant party, law enforcement agency or court: to the extent necessary for the establishment, exercise or defence of legal rights;
Any relevant party: for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
Any relevant third party acquirer(s):, in the event that we sell or transfer all or any portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
If we engage a third party processor to process your Personal Data, the processor will be subject to binding contractual obligations to: (a) only process the Personal Data in accordance with our prior written instructions; and (b) use measures to protect the confidentiality and security of the Personal Data, together with any additional requirements under applicable law.
Data security and accuracy
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
Data retention, accuracy and minimization
We take every reasonable step to ensure that your Personal Data are only processed for the minimum period necessary for the purposes set out in this Policy.
The criteria for determining the duration for which we will keep your Personal Data are as follows: we will retain copies of your Personal Data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Policy, unless applicable law requires a longer retention period. In particular, we may retain your Personal Data for the duration of any period necessary to establish, exercise or defend any legal rights.
We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.
Your legal right regarding your personal data
Subject to applicable law, you may have a number of rights regarding our processing of your relevant Personal Data, including:
The right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our website if you do not provide us with your Personal Data);
The right to request access to, or copies of, your Personal Data, together with information regarding the nature, processing and disclosure of those Personal Data;
The right to request rectification of any inaccuracies in your Personal Data;
The right to request, on legitimate grounds, erasure of your Personal Data, or restriction of processing of your Personal Data;
The right to have certain Personal Data transferred to another controller, in a structured, commonly used and machine-readable format, to the extent applicable;
Where we process your Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your Personal Data in reliance upon any other available legal bases); and
The right to lodge complaints with a relevant data protection authority regarding the processing of your Personal Data by us or on our behalf.
We may process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding our business that may be of interest to you. If we analyse an investment opportunity with you, or invest in your company, we may send information to you regarding our business and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.