Background
This
Privacy
Notice
sets
forth
how
Vanguard
Bridging
and
its
affiliates,
together
Controllers
(referred
to
collectively
as
“Vanguard Bridging” “we”, “us” or “our”), collect and process certain Personal Data.
“Personal
Data”
means
any
data
which
relates
to
a
living
individual
who
can
be
identified
from
that
data
or
from
that
data
and
other
information
which
is
in
the
possession
of,
or
is
likely
to
come
into
the
possession
of,
Vanguard
Bridging
(or
its
representatives
or
service
providers).
In
addition
to
factual
information,
it
includes
any
expression
of
opinion
about
an
individual and any indication of the intentions of Vanguard Bridging or any other person in respect of an individual.
Vanguard
Bridging
is
responsible
for
ensuring
that
it
uses
Personal
Data
in
compliance
with
data
protection
laws.
We
respect
the privacy of individuals and we are committed to keeping Personal Data secure.
This
Privacy
Notice
applies
to
non-public
personal
information
of
individuals
outside
our
organisation
with
whom
we
interact,
including but not limited to:
•
current, prospective and former investors and clients (collectively, “Investors”) and their personnel;
•
visitors to our website;
•
vendors and service providers; and
•
visitors to our offices.
These
policies
may
be
changed
at
any
time.
Changes
will
be
effective
immediately
upon
posting
onto
our
Website
for
internet
users or provided to you if visiting our offices.
Your information
This
Privacy
Notice
concerns
the
following
categories
of
information
that
we
collect
about
you
when
providing
our
products
and services (together, the “services”) and includes information we receive through our Website.
Many
of
the
services
offered
by
Vanguard
Bridging
require
us
to
obtain
Personal
Data
about
you
in
order
to
perform
the
services we have been engaged to provide.
Information
that
you
provide
to
us
will
depend
upon
the
nature
of
the
services
you
are
requesting
though
such
information
may
include
basic
Personal
Data
(such
as
full
name;
job
title;
company
name;
company
email
address;
business
phone
number; business address; city; postcode; country).
Information
that
we
collect
or
generate
about
you
includes
a
file
with
your
client
records
and
contact
history
to
be
used
for
enquiry
purposes
so
that
we
may
ensure
that
you
are
satisfied
with
the
services
which
we
have
provided
to
you;
and
details
of site and marketing/communication preferences.
Information we may obtain from other sources includes:
Website
This
will
include
information
such
as:
number
of
people
visiting
our
Website;
pages
visited;
features
used;
how
long
they
stay
and
the
websites
they
are
connecting
from;
collected
on
an
aggregate
basis
on
public
areas
of
our
Website,
or
on
an
individual
basis
on
areas
of
our
Website
that
require
Website
visitors
to
logon
using
and
access
code
(e.g.
user
ID
and/or
password).
Cookies
When you visit our Website, cookies are used to collect information about the services that you use, and how you use them.
Anonymised
data-In
addition
to
the
categories
of
Personal
Data
described
above,
we
may
also
process
further
anonymised
information and data that is not processed by reference to a specific individual.
How we use your information
Your Personal Data may be stored and processed by us for the following purposes:
•
to understand your needs and interests;
•
for
the
management
and
administration
of
our
business
including
to
improve
the
calibre
of
online
information
and
services offered;
•
to assess your application for Vanguard Bridging services, where applicable;
•
to
understand
feedback
on
Vanguard
Bridging
services
and
to
help
provide
more
information
on
the
use
of
the
services
quickly and easily;
•
to communicate with you in order to provide you with services or information about Vanguard Bridging or its services;
•
in
order
to
comply
with
and
in
order
to
assess
compliance
with
applicable
laws,
rules
and
regulations,
and
internal
policies and procedures;
•
for the administration and maintenance of databases storing Personal Data; or
•
for
ongoing
review
and
improvement
of
the
information
provided
on
our
Website
to
ensure
it
is
user
friendly
and
to
prevent any potential disruptions or cyber-attacks.
However,
when
we
use
Personal
Data
we
make
sure
that
the
usage
complies
with
the
law.
The
law
allows
us
and
requires
us
to use Personal Data for a variety of reasons, including but not limited to the following:
•
in order to perform our contractual obligations;
•
where we have obtained your consent to use the information;
•
where we have legal and regulatory obligations that we have to discharge;
•
where
we
may
need
to
do
so
in
order
to
establish,
exercise
or
defend
our
legal
rights
or
for
the
purpose
of
legal
proceedings;
•
the use of your Personal Data as described is necessary for our legitimate business interests, such as:
o
allowing us to effectively and efficiently manage and administer the operation of our business;
o
maintaining compliance with internal policies and procedures;
o
monitoring the use of our copyrighted materials;
o
enabling quick and easy access to information on Vanguard Bridging services; and,
o
obtaining
further
knowledge
of
current
threats
to
network
security
in
order
to
update
our
security
solutions
and
provide these to the market.
We
will
take
steps
to
ensure
that
the
Personal
Data
is
accessed
only
by
our
employees
that
have
a
need
to
do
so
for
the
purposes described in this Privacy Notice.
Disclosure of your information to third parties
We
may
share
your
Personal
Data
within
Vanguard
Bridging
for
the
purposes
described
above.
We
may
also
share
your
Personal Data outside of Vanguard Bridging for the following purposes:
•
with
our
affiliated
companies
or
other
trusted
businesses
or
persons
for
the
purpose
of
processing
personal
data
on
our
behalf for the above stated purposes;
•
with
our
business
partners.
Personal
Data
will
only
be
transferred
to
a
business
partner
who
is
contractually
obliged
to
comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
•
with
third-party
agents
and
contractors
for
the
purposes
of
providing
services
to
us
(for
example,
our
accountants,
professional
advisors,
IT
and
communications
providers).
These
third
parties
will
be
subject
to
appropriate
data
protection obligations and they will only use your Personal Data as described in this Privacy Notice;
•
to
the
extent
required
by
law,
for
example
if
we
are
under
a
duty
to
disclose
your
Personal
Data
in
order
to
comply
with
any
legal
obligation
(including,
without
limitation,
in
order
to
comply
with
tax
reporting
requirements
and
disclosures
to
regulators), or to establish, exercise or defend its legal rights; and
•
if
we
sell
our
business
or
assets
or
are
acquired
by
a
third
party,
in
which
case
we
may
need
to
disclose
your
Personal
Data to the prospective buyer for due diligence purposes.
International transfers of personal data
Vanguard
Bridging
is
a
global
business
with
customers
and
operations
spread
around
the
world.
As
a
result,
we
may
collect
and
transfer
Personal
Data
on
a
global
basis.
That
means
that
we
may
transfer
your
Personal
Data
to
locations
outside
of
your country.
Where
we
transfer
your
Personal
Data
to
a
country
outside
the
EEA,
we
will
ensure
that
it
is
protected
and
transferred
in
a
manner
consistent
with
European
legal
requirements.
In
relation
to
data
being
transferred
outside
of
Europe,
for
example,
this may be done in one of the following ways:
•
the
country
might
be
approved
by
the
European
Commission
as
offering
an
adequate
level
of
protection
for
Personal
Data (e.g. Israel is an approved country);
•
the
recipient
might
have
signed
up
to
a
contract
based
on
“model
contractual
clauses”
approved
by
the
European
Commission, obliging them to protect your Personal Data;
•
where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
•
in other circumstances where the law may permit us to otherwise transfer your Personal Data outside Europe.
You
can
obtain
more
details
of
the
protection
given
to
your
Personal
Data
when
it
is
transferred
outside
Europe
(including
a
copy
of
the
standard
data
protection
clauses
which
we
have
entered
into
with
recipients
of
your
Personal
Data)
by
contacting
us as described below.
Security standards – how we safeguard your information
We
work
hard
to
ensure
that
our
systems
are
secure
and
that
they
meet
industry
standards.
Where
appropriate,
we
employ
firewalls,
encryption
technology,
user
authentications
systems
(e.g.
passwords
and
personal
identification
numbers)
to
control
access
to
systems
and
data.
We
will
continue
to
assess
new
technology
to
evaluate
its
ability
to
provide
additional
protection for your Personal Data.
Access
to
our
computer
systems
is
controlled
and
restricted.
Physical
access
to
areas
where
Personal
Data
is
gathered,
processed or stored is limited to authorised employees.
As
a
condition
of
employment,
Vanguard
Bridging
staff
are
required
to
follow
all
applicable
laws
and
regulations,
including
in
relation
to
data
protection
law.
Unauthorised
use
or
disclosure
of
confidential
client
information
by
a
Vanguard
Bridging
employee is prohibited and may result in disciplinary measures.
How long we keep your personal data
The length of time we will hold your Personal Data will vary and will depend on:
•
the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
•
legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
Your rights
In
all
the
above
cases
in
which
we
collect,
use
or
store
your
Personal
Data,
you
may
have
the
following
rights
and,
in
most
cases, you can exercise them free of charge. These rights include:
•
the
right
to
obtain
information
regarding
the
processing
of
your
Personal
Data
and
access
to
the
Personal
Data
which
we hold about you;
•
the
right
to
withdraw
your
consent
to
the
processing
of
your
Personal
Data
at
any
time.
Please
note,
however,
that
we
may
still
be
entitled
to
process
your
Personal
Data
if
we
have
another
legitimate
reason
for
doing
so.
For
example,
we
may need to retain Personal Data to comply with a legal obligation;
•
in
some
circumstances,
the
right
to
receive
some
Personal
Data
in
a
structured,
commonly
used
and
machine-readable
format
and/or
request
that
we
transmit
that
data
to
a
third-party
where
this
is
technically
feasible.
Please
note
that
this
right only applies to Personal Data which you have provided directly to Vanguard Bridging;
•
the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
•
the
right
to
request
that
we
erase
your
Personal
Data
in
certain
circumstances.
Please
note
that
there
may
be
circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
•
the
right
to
object
to,
or
request
that
we
restrict,
our
processing
of
your
Personal
Data
in
certain
circumstances.
Again,
there
may
be
circumstances
where
you
object
to,
or
ask
us
to
restrict,
our
processing
of
your
Personal
Data
but
we
are
legally entitled to refuse that request; and
•
the
right
to
lodge
a
complaint
with
the
relevant
data
protection
regulator
if
you
think
that
any
of
your
rights
have
been
infringed by us.
You can exercise your rights by contacting us using the details listed below.
Use of Cookies
A
cookie
is
a
small
piece
of
information
that
an
Internet
site
sends
to
a
website
visitor’s
computer.
In
some
cases,
it
is
stored
on
the
visitor’s
computer’s
hard
drive.
Cookies
can
save
the
visitor’s
name,
password,
user-name,
screen
preferences
and
the
pages
of
the
site
viewed
by
the
visitor.
Visitors
may
decline
the
Internet
cookie
by
using
the
appropriate
feature
of
their
Web
software,
if
available.
Declining
the
Internet
cookie
may,
however,
interfere
with
a
visitor’s
ability
to
view
certain
content
is
this
web site.
Contact Us
If
you
have
any
questions
and/or
concerns
for
instance
about
the
handling
of
your
Personal
Data,
or
want
to
let
us
know
what
you think, please contact us by
Address:
Vanguard Bridging
134 Buckingham Palace Road
London
SW1W 9SA
Tel.
+44 (0)207 0963 964
Email.
data@vanguardbridging.com
Background
This
Privacy
Notice
sets
forth
how
Vanguard
Bridging
and
its
affiliates,
together
Controllers
(referred
to
collectively
as
“Vanguard
Bridging”
“we”,
“us”
or
“our”),
collect
and
process
certain Personal Data.
“Personal
Data”
means
any
data
which
relates
to
a
living
individual
who
can
be
identified
from
that
data
or
from
that
data
and
other
information
which
is
in
the
possession
of,
or
is
likely
to
come
into
the
possession
of,
Vanguard
Bridging
(or
its
representatives
or
service
providers).
In
addition
to
factual
information,
it
includes
any
expression
of
opinion
about
an
individual
and
any
indication
of
the
intentions
of
Vanguard
Bridging or any other person in respect of an individual.
Vanguard
Bridging
is
responsible
for
ensuring
that
it
uses
Personal
Data
in
compliance
with
data
protection
laws.
We
respect
the
privacy
of
individuals
and
we
are
committed
to
keeping Personal Data secure.
This
Privacy
Notice
applies
to
non-public
personal
information
of
individuals
outside
our
organisation
with
whom we interact, including but not limited to:
•
current,
prospective
and
former
investors
and
clients
(collectively, “Investors”) and their personnel;
•
visitors to our website;
•
vendors and service providers; and
•
visitors to our offices.
These
policies
may
be
changed
at
any
time.
Changes
will
be
effective
immediately
upon
posting
onto
our
Website
for
internet users or provided to you if visiting our offices.
Your information
This
Privacy
Notice
concerns
the
following
categories
of
information
that
we
collect
about
you
when
providing
our
products
and
services
(together,
the
“services”)
and
includes
information we receive through our Website.
Many
of
the
services
offered
by
Vanguard
Bridging
require
us
to
obtain
Personal
Data
about
you
in
order
to
perform
the
services we have been engaged to provide.
Information
that
you
provide
to
us
will
depend
upon
the
nature
of
the
services
you
are
requesting
though
such
information
may
include
basic
Personal
Data
(such
as
full
name;
job
title;
company
name;
company
email
address;
business
phone
number;
business
address;
city;
postcode;
country).
Information
that
we
collect
or
generate
about
you
includes
a
file
with
your
client
records
and
contact
history
to
be
used
for
enquiry
purposes
so
that
we
may
ensure
that
you
are
satisfied
with
the
services
which
we
have
provided
to
you;
and
details
of
site
and
marketing/communication
preferences.
Information we may obtain from other sources includes:
Website
This
will
include
information
such
as:
number
of
people
visiting
our
Website;
pages
visited;
features
used;
how
long
they
stay
and
the
websites
they
are
connecting
from;
collected
on
an
aggregate
basis
on
public
areas
of
our
Website,
or
on
an
individual
basis
on
areas
of
our
Website
that
require
Website
visitors
to
logon
using
and
access
code
(e.g. user ID and/or password).
Cookies
When
you
visit
our
Website,
cookies
are
used
to
collect
information
about
the
services
that
you
use,
and
how
you
use them.
Anonymised
data-In
addition
to
the
categories
of
Personal
Data
described
above,
we
may
also
process
further
anonymised
information
and
data
that
is
not
processed
by
reference to a specific individual.
How we use your information
Your
Personal
Data
may
be
stored
and
processed
by
us
for
the following purposes:
•
to understand your needs and interests;
•
for
the
management
and
administration
of
our
business
including
to
improve
the
calibre
of
online
information
and services offered;
•
to
assess
your
application
for
Vanguard
Bridging
services, where applicable;
•
to
understand
feedback
on
Vanguard
Bridging
services
and
to
help
provide
more
information
on
the
use
of
the
services quickly and easily;
•
to
communicate
with
you
in
order
to
provide
you
with
services
or
information
about
Vanguard
Bridging
or
its
services;
•
in
order
to
comply
with
and
in
order
to
assess
compliance
with
applicable
laws,
rules
and
regulations,
and internal policies and procedures;
•
for
the
administration
and
maintenance
of
databases
storing Personal Data; or
•
for
ongoing
review
and
improvement
of
the
information
provided
on
our
Website
to
ensure
it
is
user
friendly
and
to prevent any potential disruptions or cyber-attacks.
However,
when
we
use
Personal
Data
we
make
sure
that
the
usage
complies
with
the
law.
The
law
allows
us
and
requires
us
to
use
Personal
Data
for
a
variety
of
reasons,
including
but
not limited to the following:
•
in order to perform our contractual obligations;
•
where
we
have
obtained
your
consent
to
use
the
information;
•
where
we
have
legal
and
regulatory
obligations
that
we
have to discharge;
•
where
we
may
need
to
do
so
in
order
to
establish,
exercise
or
defend
our
legal
rights
or
for
the
purpose
of
legal proceedings;
•
the
use
of
your
Personal
Data
as
described
is
necessary
for our legitimate business interests, such as:
o
allowing
us
to
effectively
and
efficiently
manage
and administer the operation of our business;
o
maintaining
compliance
with
internal
policies
and
procedures;
o
monitoring the use of our copyrighted materials;
o
enabling
quick
and
easy
access
to
information
on
Vanguard Bridging services; and,
o
obtaining
further
knowledge
of
current
threats
to
network
security
in
order
to
update
our
security
solutions and provide these to the market.
We
will
take
steps
to
ensure
that
the
Personal
Data
is
accessed
only
by
our
employees
that
have
a
need
to
do
so
for
the purposes described in this Privacy Notice.
Disclosure of your information to third parties
We
may
share
your
Personal
Data
within
Vanguard
Bridging
for
the
purposes
described
above.
We
may
also
share
your
Personal
Data
outside
of
Vanguard
Bridging
for
the
following
purposes:
•
with
our
affiliated
companies
or
other
trusted
businesses
or
persons
for
the
purpose
of
processing
personal
data
on
our
behalf
for
the
above
stated
purposes;
•
with
our
business
partners.
Personal
Data
will
only
be
transferred
to
a
business
partner
who
is
contractually
obliged
to
comply
with
appropriate
data
protection
obligations
and
the
relevant
privacy
and
confidentiality
legislation;
•
with
third-party
agents
and
contractors
for
the
purposes
of
providing
services
to
us
(for
example,
our
accountants,
professional
advisors,
IT
and
communications
providers).
These
third
parties
will
be
subject
to
appropriate
data
protection
obligations
and
they
will
only
use
your
Personal
Data
as
described
in
this
Privacy Notice;
•
to
the
extent
required
by
law,
for
example
if
we
are
under
a
duty
to
disclose
your
Personal
Data
in
order
to
comply
with
any
legal
obligation
(including,
without
limitation,
in
order
to
comply
with
tax
reporting
requirements
and
disclosures
to
regulators),
or
to
establish, exercise or defend its legal rights; and
•
if
we
sell
our
business
or
assets
or
are
acquired
by
a
third
party,
in
which
case
we
may
need
to
disclose
your
Personal
Data
to
the
prospective
buyer
for
due
diligence
purposes.
International transfers of personal data
Vanguard
Bridging
is
a
global
business
with
customers
and
operations
spread
around
the
world.
As
a
result,
we
may
collect
and
transfer
Personal
Data
on
a
global
basis.
That
means
that
we
may
transfer
your
Personal
Data
to
locations
outside of your country.
Where
we
transfer
your
Personal
Data
to
a
country
outside
the
EEA,
we
will
ensure
that
it
is
protected
and
transferred
in
a
manner
consistent
with
European
legal
requirements.
In
relation
to
data
being
transferred
outside
of
Europe,
for
example, this may be done in one of the following ways:
•
the
country
might
be
approved
by
the
European
Commission
as
offering
an
adequate
level
of
protection
for Personal Data (e.g. Israel is an approved country);
•
the
recipient
might
have
signed
up
to
a
contract
based
on
“model
contractual
clauses”
approved
by
the
European
Commission,
obliging
them
to
protect
your
Personal Data;
•
where
the
recipient
is
located
in
the
US,
it
might
be
a
certified member of the EU-US Privacy Shield scheme; or
•
in
other
circumstances
where
the
law
may
permit
us
to
otherwise transfer your Personal Data outside Europe.
You
can
obtain
more
details
of
the
protection
given
to
your
Personal
Data
when
it
is
transferred
outside
Europe
(including
a
copy
of
the
standard
data
protection
clauses
which
we
have
entered
into
with
recipients
of
your
Personal
Data) by contacting us as described below.
Security standards – how we safeguard your information
We
work
hard
to
ensure
that
our
systems
are
secure
and
that
they
meet
industry
standards.
Where
appropriate,
we
employ
firewalls,
encryption
technology,
user
authentications
systems
(e.g.
passwords
and
personal
identification
numbers)
to
control
access
to
systems
and
data.
We
will
continue
to
assess
new
technology
to
evaluate
its
ability
to
provide additional protection for your Personal Data.
Access
to
our
computer
systems
is
controlled
and
restricted.
Physical
access
to
areas
where
Personal
Data
is
gathered,
processed or stored is limited to authorised employees.
As
a
condition
of
employment,
Vanguard
Bridging
staff
are
required
to
follow
all
applicable
laws
and
regulations,
including
in
relation
to
data
protection
law.
Unauthorised
use
or
disclosure
of
confidential
client
information
by
a
Vanguard
Bridging
employee
is
prohibited
and
may
result
in
disciplinary
measures.
How long we keep your personal data
The
length
of
time
we
will
hold
your
Personal
Data
will
vary
and will depend on:
•
the
purpose
for
which
we
are
using
it
–
we
will
need
to
keep
the
data
for
as
long
as
is
necessary
for
that
purpose; and
•
legal
obligations
–
laws
or
regulation
may
set
a
minimum
period
for
which
we
have
to
keep
your
Personal Data.
Your rights
In
all
the
above
cases
in
which
we
collect,
use
or
store
your
Personal
Data,
you
may
have
the
following
rights
and,
in
most
cases,
you
can
exercise
them
free
of
charge.
These
rights
include:
•
the
right
to
obtain
information
regarding
the
processing
of
your
Personal
Data
and
access
to
the
Personal
Data
which we hold about you;
•
the
right
to
withdraw
your
consent
to
the
processing
of
your
Personal
Data
at
any
time.
Please
note,
however,
that
we
may
still
be
entitled
to
process
your
Personal
Data
if
we
have
another
legitimate
reason
for
doing
so.
For
example,
we
may
need
to
retain
Personal
Data
to
comply with a legal obligation;
•
in
some
circumstances,
the
right
to
receive
some
Personal
Data
in
a
structured,
commonly
used
and
machine-readable
format
and/or
request
that
we
transmit
that
data
to
a
third-party
where
this
is
technically
feasible.
Please
note
that
this
right
only
applies
to
Personal
Data
which
you
have
provided
directly to Vanguard Bridging;
•
the
right
to
request
that
we
rectify
your
Personal
Data
if
it is inaccurate or incomplete;
•
the
right
to
request
that
we
erase
your
Personal
Data
in
certain
circumstances.
Please
note
that
there
may
be
circumstances
where
you
ask
us
to
erase
your
Personal
Data but we are legally entitled to retain it;
•
the
right
to
object
to,
or
request
that
we
restrict,
our
processing
of
your
Personal
Data
in
certain
circumstances.
Again,
there
may
be
circumstances
where
you
object
to,
or
ask
us
to
restrict,
our
processing
of
your
Personal
Data
but
we
are
legally
entitled
to
refuse that request; and
•
the
right
to
lodge
a
complaint
with
the
relevant
data
protection
regulator
if
you
think
that
any
of
your
rights
have been infringed by us.
You
can
exercise
your
rights
by
contacting
us
using
the
details
listed below.
Use of Cookies
A
cookie
is
a
small
piece
of
information
that
an
Internet
site
sends
to
a
website
visitor’s
computer.
In
some
cases,
it
is
stored
on
the
visitor’s
computer’s
hard
drive.
Cookies
can
save
the
visitor’s
name,
password,
user-name,
screen
preferences
and
the
pages
of
the
site
viewed
by
the
visitor.
Visitors
may
decline
the
Internet
cookie
by
using
the
appropriate
feature
of
their
Web
software,
if
available.
Declining
the
Internet
cookie
may,
however,
interfere
with
a
visitor’s ability to view certain content is this web site.
Contact Us
If
you
have
any
questions
and/or
concerns
for
instance
about
the
handling
of
your
Personal
Data,
or
want
to
let
us
know
what you think, please contact us by
Address:
Vanguard Bridging
134 Buckingham Palace Road
London
SW1W 9SA
Tel.
+44 (0)207 0963 964
Email.
data@vanguardbridging.com
VANGUARD
BRIDGING
VANGUARD
BRIDGING
