Setting new standards in regulatory technology

Privacy Policy

1. Introduction

1.1 This Privacy Notice gives you information about how Vaiie Limited ("we", "our", "us", "the Company") and its associated companies collect and use your personal data.

1.2 The purpose of this document is to provide you with information on our use of your personal data in accordance with the Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) 2018 Law and such other legislation as may be applicable from time to time.

1.3 This Privacy Notice sets out how the Company deals with your personal data which we collect in the course of your use of our website (vaiie.com) and as a result of interacting with the Company and its associates in other ways. We may collect certain information about you in the course of your use of our website and otherwise in your interaction and correspondence with us. We take privacy and security of your information seriously and will only use such personal information as set out in this privacy policy or in other supplemental privacy policies which we may provide from time to time when offering and/or providing specific services to you.

1.4 This privacy policy may be updated from time to time. The definitive version of this policy will always be the one published on our website from time to time.

 

2. What data we collect

2.1 Depending on the nature of our relationship with you, we will collect various types of personal information about you which may include some or all of the following:

2.1.1 Your identification information (which may include your name, ID card and passport numbers, nationality, place and date of birth, gender, photograph and/or IP address and personal information relating to claims, court cases and convictions, politically exposed person (PEP) status, personal information available in the public domain and such other information as may be necessary for us to provide our services and to complete any client due diligence process and discharge any AML/CFT/CPF obligations);

2.1.2 Your tax status information (which may include your tax residency, tax ID and tax status);

2.1.3 Your contact information (which may include postal residential and business addresses, personal and business e-mail address and your home, business and mobile telephone numbers);

2.1.4 Your family relationships (which may include your marital status, the identity of your spouse and the number of children that you have);

2.1.5 Your professional and employment information (which may include your level of education and professional qualifications, your employment, employer’s name and details of directorships and other offices which you may hold);

2.1.6 Financial information, sources of wealth and your assets (which may include details of your assets, sources of wealth, shareholdings and your beneficial interest in assets, your bank details and your credit history);

2.1.7 Biometric data including facial and voice recognition (this data is stored only in the form of photographs and videos;

2.1.8 Transaction data including details about payments to and from you and other details of services you have obtained from us;

2.1.9 Profile data including profile pictures, usernames and passwords, details of services, your interests and preferences; and

2.1.10 IP Address (we may collect your IP (Internet Protocol) address to help diagnose problems with our server, and to administer our Site. An IP address is a number that is assigned to your computer when you use the Internet. This information does not contain any personally identifiable information about you. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.  We may also collect usage data including information about how you interact with and use our website and services and marketing and communications data including your preferences for receiving marketing communications from us and our third parties. We will also collect geo-location data (latitude/longitude) if used as part of address verification.

2.2 We may collect and process personal information regarding people connected to you, either by way of professional (or other) association or by way of family relationship.

2.3 We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymous data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

 

3. Where we obtain your personal data

3.1 We collect your personal information from the following sources:

3.1.1 personal information which you give to us, including but not limited to:

  1. on such other forms and documents as we may request you complete or provide in relation to any of our services;
  2. information gathered through client due diligence carried out as part of our compliance with regulatory requirements; or
  3. any personal information provided by way of correspondence with us by phone, e-mail or otherwise;

3.1.2 personal information we receive from third party sources, such as:

  1. entities in which you or someone connected to you has an interest;
  2. your legal and/or financial advisors;
  3. other financial institutions who hold and process your personal information;
  4. other publicly available sources such as Companies House, the Jersey Financial Services Registry etc; and
  5. credit reference agencies and financial crime databases for the purposes of complying with our regulatory requirements.

3.1.3 personal information received in the course of dealing with advisors, regulators, official authorities, payment providers and service providers by whom you are employed or engaged or for whom you act.

 

4. Use of cookies

4.1 Our site makes use of cookies to distinguish you from other users of our website. This helps us to provide you with a positive experience when you browse our website and allows us to improve our site. For a more detailed information on the cookies we use and the purposes for which we use them see our cookie policy.

4.2 'Cookies' are small pieces of information sent by an organisation to your computer and stored on your hard drive to allow that website to recognise you when you visit. They collect statistical data about your browsing actions and patterns and do not identify you as an individual.

4.3 It is possible to turn off cookies by setting your browser preferences. Turning cookies off may result in reduced functionality when using our website.

 

5. Why we collect your Personal data

 Lawful grounds for processing

5.1 We are entitled to hold and process your personal data on the following lawful grounds:

5.1.1 the processing is necessary for our legitimate interests provided your interests and fundamental rights do not override our legitimate interests;

5.1.2 the processing is necessary to comply with our legal obligations including in any employment or social field;

5.1.3 the processing is necessary for the performance of a contract to which you are a party, or to take such steps, at your request, with a view to entering you into such a contract;

5.1.4 the processing is necessary to exercise, bring or defend a legal claim or to prevent and detect an unlawful act;

5.1.5 to comply with our legal and regulatory obligations (and those of our service providers);

5.1.6 (on exceptional occasions) where we have obtained your consent;

5.1.7 on rare occasions, where we need to protect your interests (or someone else's interests); and

5.1.8 on rare occasions, where it is needed in the public interest.

Some of the above grounds for processing described above will overlap and there may be several grounds which justify our use of your personal data.

Purposes of processing

5.2 Pursuant to paragraph 5.1, we may process your personal data, for the purposes set out below ("Purposes"). Those based wholly or partly on our legitimate interests are set out in paragraphs 5.2.1  to 5.2.6 inclusive):

5.2.1 facilitating the internal administration of our business, clients and/or our service providers;

5.2.2 communicating with you as necessary in connection with our services or in relation to a contract we have in place with you;

5.2.3 operating IT systems, software and business applications;

5.2.4 supporting our IT and business applications support teams, accounting, legal, reporting, internal audit and risk management, administrative, transfer, document storage, record keeping and other related functions, including but not limited to processing personal data in connection with the Company;

5.2.5 monitoring and recording telephone and electronic communications and transactions:

  1. for quality, business analysis, training and related purposes in order to improve service delivery;
  2. for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act);

5.2.6 disclosing your personal data to any bank or financial institution in providing our services;

5.2.7 to enforce or defend our legal rights, or those of third parties to whom we each may delegate responsibilities or rights in order to comply with a legal or regulatory obligations imposed on each of us;

5.2.8 collecting, processing, transferring and storing "customer due diligence", source of funds information and verification data under applicable anti-money laundering and terrorist financing laws and regulations; and

5.2.9 liaising with or reporting to any regulatory authority (including tax authorities) with whom we either are required to cooperate with, report to or with whom we decide or deem it is appropriate to cooperate.

5.3 We will only use your personal data for the Purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where these are required or permitted by applicable laws.

5.4 To the extent that such personal data contains special category data such as, for example: data relating to racial or ethnic origin, political opinion, religious or philosophical belief, trade union membership or criminal data then the processing of such data shall solely be for the purpose of complying with any duty imposed on the Company (or on any service provider appointed by either of them) by an enactment including, but not limited to, legislation and regulatory obligations relating to Anti-Money Laundering and Combatting the Financing of Terrorism and all other related legislation.

 

6. Sharing personal data

6.1 We may share your personal information:

6.1.1 within our group of companies including to our affiliates;

6.1.2 with third party service providers, including, our insurers and insurance agents, banks, financial institutions or other third party lenders, IT service providers, auditors and legal professionals to facilitate our business and the services which we provide;

6.1.3 where we are subject to a legal obligation that necessitates the sharing of this information with parties such as our regulatory authorities, tax and revenue authorities, companies registries, governmental departments, courts and law enforcement authorities; or

6.1.4 in the context of a merger, sale or acquisition, or other change in our organisational structure.

6.2 Where we transfer your personal data outside Jersey and the European Economic Area ("EEA"), we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information. This can be done in a number of different ways, for instance:

6.2.1 the country to which we send the personal data may be approved by the European Commission as providing adequate protection for personal data; or

6.2.2 by utilising a contract based on "model contractual clauses" approved by the European Commission.

6.3 In other circumstances, the law may permit us to otherwise transfer your personal data outside Jersey or the EEA.

6.4 If you would like further information about the safeguards we have in place to protect your personal data, please contact our Data Protection Officer by e-mail at privacy@vaiie.com or call us on +44(0) 1534 617527.

 

7. Retention of personal data

7.1 Your personal data will be retained as long as required:

7.1.1 for the Purposes for which the data was collected;

7.1.2 in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations; and/or

7.1.3 as required by data protection laws and any other applicable laws or regulatory requirements.

7.2 We endeavor to store your personal data securely in accordance with accepted market standards.

7.3 For further information about applicable retention periods, please contact the Data Protection Officer by e-mail at privacy@vaiie.com or call us on +44(0) 1534 617527.

 

8. Access to and control of personal data

8.1 You have the right, under certain circumstances, to the following rights in respect of personal data:

8.1.1 the right to access and port personal data;

8.1.2 the right to rectify personal data;

8.1.3 the right to restrict the use of personal data;

8.1.4 the right to request that personal data is erased;

8.1.5 the right not to be subject to a decision based solely on the automated processing by us of your personal data;

8.1.6 the right to object to processing of personal data (in particular for marketing purposes or where it is processed in our legitimate interest);

8.1.7 the right to withdraw consent;

8.1.8 the right to compensation where we or another organisation has caused you damage as a result of our processing of your personal data; and

8.1.9 the right to seek a judicial (i.e. court) remedy where you consider we have acted or are about to act in breach of the relevant data protection legislation.

8.2 You also have the right to lodge a complaint about the processing of your personal data either with us, with the Jersey Office of the Information Commissioner (https://jerseyoic.org/) or the relevant data protection supervisory authority either in the country/territory in which you are located and/or in the jurisdiction in which we are located and process your personal data.

8.3 You can contact the Jersey Office of the Information Commissioner at the following address:

5 Castle Street

St. Helier, Jersey JE2 3BT

Or by telephone at +44 1534 716530 or by email at enquiries@jerseyoic.org.

8.4 Whenever you are considering lodging a complaint however we should please be grateful if you would first allow us the opportunity to resolve your complaint by addressing it in writing, and providing as much detail as possible, to Vaiie Limited, 4 Britannia Place, Bath Street, St Helier, Jersey, JE2 4YS or by email to privacy@vaiie.com.

 

9. Right to withdraw consent 

In the limited circumstances we may approach you for your written consent to allow us to process certain particularly data or to use data for another purpose. Where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact our Data Protection Officer by e-mail at privacy@vaiie.com or call us on +44(0) 1534 617527. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

 

10. Data protection lead

10.1 We have appointed a Data Protection Lead to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal data, please contact s by e-mail at privacy@vaiie.com or call us on +44(0) 1534 617527. You have the right to make a complaint at any time.

10.2 If you have any questions about our use of your personal data, our retention procedures or our security processes, please contact our Data Protection Officer via e-mail at privacy@vaiie.com or call us on +44(0) 1534 617527.

 

11. Inaccurate or amended information

11.1 Please let us know as soon as possible if any of your personal information changes (including your correspondence details).

11.2 Failure to provide accurate information or to update information when it changes may have a detrimental impact upon our ability to provide services.

11.3 You can change your marketing preferences at any time by unsubscribing from emails, or by emailing us at privacy@vaiie.com.

11.4 You can choose to request to delete your account and associated profile by emailing the data controller with whom you consented to be registered with Vaiie or by emailing privacy@vaiie.com.

 

12. Changes to this Policy

12.1 This Privacy Notice is dated 1 February 2025.   

12.2 We reserve the right to amend this Privacy Notice at any time without notice, in which case the date of the policy will be revised.