Policies

Privacy Notice – Venn Partners LLP

Venn Partners LLP is committed to being transparent about how it collects and uses the personal data of the clients and business partners we engage with. This notice sets out the basis on which we collect, process and store the personal data of our stakeholders, in line with our obligations under the General Data Protection Regulation and any other applicable data protection laws. The privacy of our clients’ information is paramount to us, and we take a range of steps to maintain the security of that data, and to ensure that clients are fully informed about the controls we have in place, along with their rights.

Where a client engages with us through one of our subsidiaries, we may provide an additional Privacy Notice that specifically considers the types of data processing we perform through that entity. Regardless of which Privacy Notice a client is covered under, we implement consistent protections for the data we process.

Types of personal data

As part of our engagement with clients and business partners, Venn Partners LLP may collect the following personal data:

• Name, address, contact numbers and email addresses;
• Date and place of birth;
• Nationality;
• Gender;
• Marital status;
• Copies of identity documents (including passports, national ID cards, and driving licences);
• Employment details and history;
• Business interests;
• Sources of wealth (including property and other assets);
• Utility bills and bank statements;
• Tax residency particulars; and
• Bank account and payment details.

In relation to our websites, we may collect technical information from any person or system connecting to our web servers, including: source IP addresses; browser types, settings and plugins; and operating system settings and versions.

Collection of personal data

Personal data relating to clients and business partners is collected directly from them, but may be obtained through third parties, such as their employer or company. Personal data may also be obtained from unconnected third parties, including but not limited to, credit reference agencies, vetting agencies, and public and commercial registers.

For our websites, the data is sent to us automatically as part of the communication mechanism behind HTTP and HTTPS traffic. Further information is available within our Cookie Policy.

Use of personal data

We primarily collect personal data in order to facilitate or fulfil a contract in which Venn Partners LLP provides services to clients and business partners. Data will be processed as part of our legitimate interests, in order to better provide services to our clients, and to allow for the smooth operation of our company. Examples of where data could be used would be customer due diligence checks, or making payments to clients and business partners, where necessary.

Personal data may also be used for informational and marketing purposes, in which we inform prospective and existing clients about developments in the offerings of Venn Partners LLP. This will only take place where we have obtained your consent to receive such communications, noting that your consent may be withdrawn at any time.

Furthermore, there may be occasions on which we have to use personal data to fulfil a legal obligation imposed on us.

In the case of our website, the collection of data is required for the proper functioning of the service.

Redistributing personal data

Personal data may be disclosed with any of our subsidiaries, and to any subcontractor that is involved in the delivery of our service to our clients. Where we use a subcontractor, we will have entered into a data processing agreement that stipulates the use for the personal data, while providing assurances around the security and integrity of that data.

International transfers and storage of personal data

Venn Partners LLP does not directly transfer data outside of the European Economic Area (EEA) or the United Kingdom (UK), as part of its processing of personal and identifiable information. All data is located in physical form within the company’s offices, or on dedicated servers hosted principally within the United Kingdom (UK), and exceptionally within the European Union (EU). Where subcontractors transfer data outside of the EEA or UK, we will consider the safeguards they have in place for the transfer and processing of that data.

Retention of personal data

Data obtained to fulfil a contract is retained for the duration of the contract. This may be extended if further processing is required in order to comply with a legal obligation or to defend a legal claim. Thereafter, personal data will be securely destroyed, in line with company policy.

In the case of direct marketing, your details will be retained for a duration that is the shorter of the time that Venn Partners LLP offers services that it reasonably expects to be of interest to you, or until you withdraw your consent for us to communicate with you in that manner.

Data obtained through our website logging is retained for no more than 14 months.

Your rights

Under data protection legislation, you have a number of rights in relation to the data that we hold about you, which may be freely exercised at a time of your choosing. You may write to us by post or by email to request us to:

• send you a copy of the data we hold about you;
• correct any incorrect data we hold about you;
• delete any data we hold about you; or
• restrict the processing of your data.

You may also object to us processing your data at any time. For the avoidance of doubt, we do not use profiling or employ automated decision making.
We will respond to you in a timely manner, confirming that your request has been carried out and supplying you with any relevant documentation, or we will notify you with a reason as to why we have not followed your request.

Should you believe that your request has not been adequately addressed by Venn Partners LLP, you can notify the Information Commissioner’s Office within the United Kingdom, the details of which are at the foot of this notice.

Protection of personal data

Venn Partners LLP has a range of organisational controls and technical solutions in place to protect the confidentiality, integrity and availability of data. Privacy is built into our processing activities by design. Details on the protection of data are contained within our Data Security Policy.

We also undertake regular training and awareness sessions with our personnel, to ensure they are fully versed with the company’s procedures for handling personal data.

Changes to this notice

The latest version of this notice will always be visible on our website. A paper or electronic copy may also be requested by post and/or email.

Contacting us

If you have any questions or concerns in relation to the processing of your personal data, you can contact our appointed data protection representative by email using the address moc.srentrap-nnevnull@ycavirp, or by sending us post to:

We will aim to respond on the next business day. You also have the right to approach the United Kingdom’s Information Commissioner, whose office is at:

For reference, our Data Protection No is Z1862023.

Complaints Handling Policy – Venn Partners LLP

You should contact us immediately if you are dissatisfied with any aspect of the investment services provided to you by Venn Partners LLP.

Please write to Complaints Contact:

We take every complaint seriously and your complaint will be handled in accordance with the relevant FCA rules, which may differ depending upon your status, although note that it is Venn Partners LLP’s policy to aim to resolve every complaint fairly and in a timely manner. Venn Partners LLP has a written internal complaints handling policy, as required by the FCA rules. You can obtain a copy of this upon request, and in the event you should have cause for complaint about the investment services that Venn Partners LLP provides to you, a copy of the policy will be sent to you.

In the event we fail to resolve a complaint to your satisfaction, or if we fail to do so within eight weeks of receiving your complaint, you may also be entitled to refer your complaint to the Financial Ombudsman Service:

Cookie Policy – Venn Partners LLP

When you visit the Venn Partners website, we may download cookies to assist us with the monitoring and maintenance of our site. A cookie is a small file consisting of letters and numbers that is stored by your web browser or on the hard drive of your computer, if you agree.

The cookies we download are part of Google Analytics, and allow us to improve our website by providing analysis and trends around how you interact with the site. Further information on how these cookies are used is available from: https://support.google.com/analytics/answer/6004245

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. This may prevent you from taking full advantage of our website. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you log on to our website.

Further information on cookies in general is available at: https://www.aboutcookies.org/

Privacy Notice – VSK Holdings Limited

VSK Holdings Limited (“we”, “us”, or “Company”) are committed to being transparent about how we collect and use the personal data of the investors and other relevant individuals we engage with (“Clients”). This notice sets out the basis on which we collect, process and store the personal data of our Clients, in line with our obligations under the Cayman Islands data privacy and protection laws and applicable US and non-US privacy laws and any other applicable data protection laws.

The privacy of our Clients’ information is paramount to us, and we take a range of steps to maintain the security of that data, and to ensure that clients are fully informed about the controls we have in place, along with their rights. Where a Client is an institutional investor, then we may process personal data about the directors, officers and ultimate beneficial owners of the institutional investor. This notice also explains how we process personal data about these individuals and will be relevant to them. Clients who provide us with personal data about individuals connected with them should provide such individuals with a copy of this notice or otherwise advise them of its content. The Company is legally responsible for the proper handling of your personnel information.

Types of personal data

As part of our engagements with Clients the Company may collect the following personal data and any other information that is required by law or a regulator:

• Name, address, contact numbers and email addresses;
• Date and place of birth;
• Nationality;
• Gender;
• Marital status;
• Copies of identity documents (including passports, national ID cards, and driving licences);
• Employment details and history;
• Business interests;
• Sources of wealth (including property and other assets);
• Utility bills and bank statements;
• Tax residency particulars; and
• Bank account and payment details.

Collection of personal data

Personal data relating to Clients is collected directly from them, but may be obtained through third parties, such as their employer or company. Personal data may also be obtained from unconnected third parties.

Use of personal data

We primarily collect personal data in order to facilitate or fulfil a contract in which the Company has undertaken or in connection with an investment in the Company. Data will be processed as part of our legitimate interests and to allow for the operation of the Company. Furthermore, there may be occasions on which we have to use personal data to fulfil a legal or regulatory obligation imposed on us.

Redistributing personal data

Personal data may be disclosed with any of our subsidiaries, and to any subcontractor that is involved in the operations of the Company and/or subsidiaries and its services. This may include our administrators, accountants, auditors, bankers, custodians, fiscal agents, insurers, lawyers, AML service providers, tax information exchange service providers and other back-office service providers. We may also share personal data with relevant regulatory authorities and tax authorities. We anticipate sharing of information outside of the Cayman Islands, primarily within the European Economic Area. Any transfer of personal data shall be in accordance with applicable data protection laws.

Retention of personal data

The Company will process and store the relevant personal data for the duration of a service or for the duration of a business relationship. We may also store the data for as long as it is necessary or required in order to fulfil legal, contractual or statutory obligations and, or for the establishment, exercise or defence of legal claims, and in general where it has a legitimate interest for doing so.

Your rights

Under data protection legislation, you have a number of rights in relation to the data that we hold about you, which may be freely exercised at a time of your choosing. You may write to us by post or by email to request us to:

• send you a copy of the data we hold about you;
• correct any incorrect data we hold about you;
• delete any data we hold about you; or
• restrict the processing of your data.

You have the right to access the personal information that the Company holds about you at any time. We will respond to you in a timely manner, confirming that your request has been carried out and supplying you with any relevant documentation, or we will notify you with a reason as to why we have not followed your request.

Should you believe that your request has not been adequately addressed by the Company, you can notify the Cayman Islands supervisory authority, the details of which are at the foot of this notice.

Protection of personal data

We take seriously the obligation to safeguard your non-public personal information. We maintain physical, electronic, and procedural safeguards to protect against unauthorized access to your information. We endeavour to restrict access to non-public personal information about you to those members associated with the Company.

Changes to this notice

We may revise this Privacy Notice from time to time to reflect changes in law or changes in how we run our business, but where such revision becomes necessary in the future.

Contacting us

If you have any questions or concerns in relation to the processing of your personal data, you can contact our appointed data protection representative by email using the address moc.srentrap-nnevnull@ycavirp, or by sending us post to:

A secondary copy of your correspondence may also be delivered electronically to moc.srentrap-nnevnull@ycavirp. We will endeavour to respond satisfactorily to any request, query, or complaint you may have in respect of your personal information, but if you are dissatisfied with our response and wish to make a formal complaint, or if you simply wish to learn more about your rights, you can contact the Cayman Islands Ombudsman:

Job Applicant Privacy Notice – November 2024

PDF Document

Venn Partners LLP (“Venn” or the “Firm”)

The Firm is aware of its obligations under the General Data Protection Regulation (the “GDPR”) and is committed to processing your data securely and transparently. This privacy notice sets out, in line with GDPR, the types of data that the Firm will collect and hold on you as a job applicant. It also sets out how we use that information, how long we keep it for and other relevant information about your data.

Data controller details:

The Firm is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows:

Data Protection Principles:

In relation to your personal data, the Firm will:

• process it fairly, lawfully and in a clear, transparent way;
• collect your data only for reasons that we find proper for the course of your employment in ways that have been explained to you;
• only use it in the way that we have told you about;
• ensure it is correct and up to date;
• keep your data for only as long as we need it; and
• process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed

Types of data the firm processes:

The Firm may hold many types of data about you, including:

• your personal details including your name, address, date of birth, email address, telephone numbers;
• gender;
• marital status;
• whether or not you have a disability;
• information included on your CV including references, education history and employment history; and
• documentation relating to your right to work in the UK

How the firm collects your data:

The Firm collects data about you in a variety of ways including the information you would normally include in a CV or a job application cover letter, or notes made by our recruitment team during a recruitment interview. Further information will be collected directly from you when completing forms at the start of your employment, for example, your bank and next of kin details. Other details may be collected directly from you in the form of official documentation such as your driving licence, passport or other right to work evidence.

In some cases, the Firm will collect data about you from third parties, such as employment agencies and former employers when gathering references or credit reference agencies.

Personal data is kept in personnel files and within the Firm’s IT systems.

Why the firm processes your data:

The law on data protection allows the Firm to process your data for certain reasons only:

• in order to perform the employment contract that we are party to;
• in order to carry out legally required duties;
• in order for us to carry out our legitimate interests;
• to protect your interests; and
• where something is done in the public interest.

All of the processing carried out by the Firm falls into one of the permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.

The Firm needs to collect your data to ensure we are complying with legal requirements such as:

• carrying out checks in relation to your right to work in the UK; and
• making reasonable adjustments for disabled employees.

The Firm also collects data so that we can carry out activities which are in the legitimate interests of the Firm, such as:

• making decisions about who to offer employment to;
• making decisions about salary and other benefits;
• assessing training needs; and
• dealing with legal claims made against us.

If you are unsuccessful in obtaining employment, the Firm will seek your consent to retaining your data in case other suitable job vacancies arise in the Firm, for which we think you may wish to apply. You are free to withhold your consent to this and there will be no consequences for withholding consent.

Special categories of data:

Special categories of data are data relating to your:

• health;
• race;
• ethnic origin;
• political opinion;
• religion;
• sex life;
• sexual orientation;
• trade union membership; and
• genetic and biometric data.

The Firm must process special categories of data in accordance with more stringent guidelines. Most commonly, the Firm will process special categories of data when the following applies:

• you have given explicit consent to the processing;
• we must process the data in order to carry out our legal obligations;
• we must process data for reasons of substantial public interest; or
• you have already made the data public.

The Firm will use your special category data for the purposes of equal opportunities monitoring.

The Firm does not need your consent if we use special categories of personal data in order to carry out our legal obligations or exercise specific rights under employment law. However, the Firm may ask for your consent to allow us to process certain particularly sensitive data. If this occurs, you will be made fully aware of the reasons for the processing. As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.

Criminal conviction data:

The Firm will only collect criminal conviction data where it is appropriate given the nature of your role and where the law permits us. This data will usually be collected at the recruitment stage, however, may also be collected during your employment should you be successful in obtaining employment. Where the Firm seeks this information, we do so because it is necessary for us to carry out our obligations and exercise specific rights in relation to employment. The Firm uses criminal conviction data in order to assess the suitability of a candidate, to make informed recruitment decisions, and to minimise any undue risk to the Firm.

If you do not provide your data to the firm:

One of the reasons for processing your data is to allow the Firm to carry out an effective recruitment process. Whilst you are under no obligation to provide the Firm with your data, we may not be able to process, or continue with (as appropriate), your application.

Sharing your data:

Your data will be shared with colleagues within the Firm where it is necessary for them to undertake their duties with regard to recruitment. This includes, for example, those dealing with HR, those in the department where the vacancy is who are responsible for screening your application and interviewing you, and those dealing with IT where you require access to the Firm’s systems to undertake any assessments requiring IT equipment.

In some cases, the Firm will collect data about you from third parties, such as employment agencies. Your data will also be shared with third parties if you are successful in your job application. In these circumstances, the Firm will share your data in order to obtain references and complete appropriate background checks as part of the recruitment process.

The Firm does not share your data with bodies outside of the European Economic Area.

Protecting your data:

The Firm is aware of the requirement to ensure your data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such. Details of these can be found in the Firm’s Data Protection and Data Security policies.

Where the Firm shares your data with third parties, we provide written instructions to them to ensure that your data is held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.

How long the firm keeps your data for:

In line with data protection principles, the Firm only keeps your data for as long as we need it for and this will depend on whether or not you are successful in obtaining employment with us.

If your application is not successful and the Firm has not sought consent, or you have not provided consent upon the Firm’s request to keep your data for the purpose of future suitable job vacancies, we will keep your data for 6 months once the recruitment exercise ends.

If the Firm has sought your consent to keep your data on file for future job vacancies, and you have provided consent, the Firm will keep your data for 12 months once the recruitment exercise ends. At the end of this period, the Firm will delete or destroy your data, unless you have already withdrawn your consent to our processing of your data in which case it will be deleted or destroyed upon your withdrawal of consent.

If your application is successful, your data will be kept and transferred to the systems the Firm administers for employees. The Firm has a separate privacy notice for employees, which will be provided to you.

Automated decision making:

No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.

Your rights in relation to your data:

The law on data protection gives you certain rights in relation to the data that the Firm holds on you. These are:

• the right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice;
• the right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request;
• the right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it;
• the right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it;
• the right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
• the right to portability. You may transfer the data that we hold on you for your own purposes;
• the right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests; and
• the right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in a way that adversely affects your legal rights.

Where you have provided consent to the Firm’s use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that the Firm will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, the Firm may continue to use the data where so permitted by having a legitimate reason for doing so.

If you wish to exercise any of the rights explained above, please contact Luke Venables, COO.

Making a complaint:

The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by the Firm, you are able to make a complaint to the ICO.

Information Commissioner’s Office

For reference, the Firm Data Protection No is Z1862023.