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), 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 within the United Kingdom. Where subcontractors transfer data outside of the EEA, 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: http://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:

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: