1. Introduction

1.1 As part of our day-to-day business and other activities we sometimes need to collect personal information from our clients and potential clients to ensure that we can meet their needs for THE range of services and products offered by us and provide them with information about our services.

1.2 Your privacy is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals. This policy outlines how we manage your personal information supplied to us by you or a third party in connection with the services we provide you or which we collect from your use of our services. It also details your rights in respect of our processing of your personal information.

1.3 This privacy policy will be reviewed from time to time to take account of new obligations and technology, changes to our operations and practices and to make sure it remains appropriate to the changing regulatory and legal environment. Any personal information we hold will be governed by our most current privacy policy.

1.4 Any reference to “us”, “our”, “we” or “Vehemence” in this privacy policy is a reference to us as the context requires unless otherwise stated.

1.5 Similarly, any reference to “you”, “your”, “yours” or “yourself” in this privacy policy is a reference to any of our clients and potential clients as the context requires unless otherwise stated.

2. Who Are We

This privacy policy applies to the processing activities of Vehemence Ltd.
Vehemence Ltd is a company registered in England and Wales with company number 10891803.

2.1 What kind of personal information do we collect
As part of providing services, or information about our services, to you, we may need to verify your identity to set you up as a client. This may include third parties carrying out credit (if applicable) or identity checks on our behalf.
If you are an actual or potential client, we may collect the following types of information about you:

• name, address and contact details
• date of birth and gender
• location data
• any other similar information

We obtain this information in a number of ways through your use of our services or other dealings with us including through any of the Vehemence Ltd websites and mobile applications and from information provided in the course of ongoing client service correspondence. We may also collect this information about you from third parties either through bought-in third party marketing lists or publicly available sources.

We may also obtain personal information about you through your use of our websites, apps or through the use of cookies on our websites and our/or apps, in particular by recording which pages you look at on our websites.
We may ask for other personal information voluntarily from time to time (for example, through market research, surveys or special offers). If you choose not to provide the information we need to fulfil your request for a specific product or service, we may not be able to provide you with the requested product or service.

To help us improve and monitor our products and services, including client services, and develop and market new products and services, we may from time to time use personal information provided by you through your use of the services and/or through client surveys to help us improve our products and services. It is in our legitimate interests for us to use your personal information in this way to ensure that we provide you with the best products and services we can to you.

We may record any communications, electronic, by telephone, in person or otherwise, that we have with you in relation to the services we provide to you and our relationship with you. These recordings will be our sole property and will constitute evidence of the communications between us. Such telephone conversations may be recorded without the use of a warning tone or any other further policy.

2.2 Who may we disclose personal information to?
As part of using your personal information for the purposes set out above, we may disclose your information to:

• service providers and specialist advisers who have been contracted to provide us with administrative, IT, financial, regulatory, compliance, insurance, research or other services
• anyone authorised by you

Generally, we require that organisations outside Vehemence Ltd who handle or obtain personal information acknowledge the confidentiality of this information, undertake to respect any individual’s right to privacy and comply with the all relevant data protection laws and this privacy policy.

Third party service providers such as credit referencing agencies may keep a record of any searches performed on our behalf and may use the search details to assist other companies in performing their searches.

Please note that the use of your personal information by external third parties who act as data controllers of your personal information is not covered by this privacy policy and is not subject to our privacy standards and procedures.

2.3 How do we obtain your consent?
Where our use of your personal information requires your consent, such consent will be provided in accordance with the applicable contract we may have entered into with you or as set out in our communication with you from time to time. 

If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time by contacting us using the contact details set out in this privacy policy. This is set out in 2.10 “How to Contact Us”.

2.4 Management and use of Personal information
We always take appropriate technical and organisational measures to ensure that your information is secure. In particular, we train our employees who handle personal information to respect the confidentiality of client information and the privacy of individuals. We regard breaches of your privacy very seriously and will impose appropriate penalties, including dismissal where necessary.

We may from time to time use personal information about you to form profiles about you so that we can provide the very best products and services we can.

Our Web pages and e-mails may contain web beacons or pixel tags or any other similar type of data analysis tools which allow us to track receipt of correspondence and to count the number of users that have visited our webpage or opened our correspondence. Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However, where your personal information is not in an anonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure that the products and services we provide are relevant to you.

We may use your personal information to send you marketing communications by email or phone or other agreed forms (including social media campaigns) to ensure that you are always kept up to date with our latest products and services. Where we send you marketing communications we will either do so as it is in our legitimate interest or with your consent.

2.5 Your Rights about Your personal information

Access
If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable administration fee.

Rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal information with others, we will let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Erasure
You can ask us to delete or remove your personal information in certain circumstances such as where we no longer need it, or you withdraw your consent (where applicable) provided that we have no legal obligation to retain that data. Such request will be subject to any retention limits we are required to comply with in accordance with applicable laws and regulations. If we have shared your personal information with others, we will let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Processing restrictions
You can ask us to “block” or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It will not stop us from storing your personal information though. We will tell you before we lift any restriction. If we have shared your personal information with others, we will let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you who we have shared your personal information with so that you can contact them directly.

Objection
You can ask us to stop processing your personal information, and we will do so, if we are:
relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;

• processing your personal information for direct marketing; or
• processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

Automated decision-making and profiling
If we have made a decision about you based solely on an automated process (e.g. through automatic profiling) that affects your ability to use the services or has another significant effect on you, you can ask not to be subject to such a decision unless we can demonstrate to you that such decision is necessary for entering into, or the performance of, a contract between you and us. Even where a decision is necessary for entering into or performing a contract, you may contest the decision and request human intervention.

2.6 How do we store personal information and for how long?
Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, by mail, over the internet or by any other electronic medium. We hold personal information in a combination of secure computer storage facilities, paper-based files and other records and take steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.

When we consider that personal information is no longer needed, we will remove any details that will identify you and will securely destroy the records.

Where you have written to us to opt out of receiving marketing communications we will hold your details on our exclusion list so that we know you do not want to receive these communications.

2.7 What is a cookie and how do we use cookies?
Cookies are small pieces of text stored on your computer or device when you visit a website or an app.
We may use cookies on our websites and on our apps to provide you with a more relevant and effective experience, including presenting web pages according to your needs or preferences.

2.8 Technology Improvements
We are constantly striving to improve functionality on our website through technology changes. This may mean a change to the way in which personal information is collected or used. The impact of any technology changes which may affect your privacy will be notified in this privacy policy at the time of the change.

2.9 What if you have a complaint and matters relating to dispute resolution and enquiries.
We may need to use personal information collected from you to investigate issues and/or settle disputes with you as it is in our legitimate interests to ensure that issues and/or disputes get investigated and resolved as quickly and efficiently as possible.

We may need to use your personal information to comply with applicable law, court order or other judicial process, or the requirements of any applicable regulatory authority. We do this not only to comply with our legal obligations but because it may also be in our legitimate interest to do so.

If you have a concern about any aspect of our privacy practices, you can make a complaint. This will be acted upon promptly. To make a complaint, please contact us via email at revolution@vehemenceco.com.

If you are not satisfied with our response to your complaint, you have the right to lodge a complaint with the Information Commissioners Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

We may need to use personal information collected from you to investigate issues and/or settle disputes with you as it is in our legitimate interests to ensure that issues and/or disputes get investigated and resolved as quickly and efficiently as possible. This is to comply with our legal obligations and because it may also be in our legitimate interest to do so.

2.10 How to contact us
If you have any questions about this privacy policy or want to exercise your rights, please contact us by:

• email at revolution@vehemenceco.com

2.11 Access policy
You will take all reasonable steps to ensure that no computer viruses, worms, software bombs or similar items are introduced into any computer hardware, software, applications, equipment or network facilities you use to access our Platforms.

We and our licensors (as the case may be) will retain the intellectual property rights in all elements of the software and such software and databases contained within our trading platforms, and you will not in any circumstances obtain title or interest in such elements.

This policy and all our dealings with you are in all respects governed by and construed and interpreted in accordance with English law, and the courts of England and Wales will have non-exclusive jurisdiction to settle any legal action or proceedings arising out of or in connection with this policy, including any noncontractual disputes and claims. Nothing in this term will prevent us from bringing proceedings against you in any other jurisdiction.