Privacy and Cookies

Please read this Privacy and Cookies Policy, along with our Conditions of Use, then return to the main site (click ‘Home’) and click the ‘I Agree’ button.

‘Vantage’, ‘we’, ‘us’ and ‘our’ means Vantage Infrastructure (UK) Limited and its affiliate Vantage Infrastructure (USA) Inc. and we are committed to respecting your privacy.

Vantage Infrastructure (UK) Limited is located in the UK with a registered address at 18th Floor, Tower 42, 25 Old Broad Street, London, EC2N 1HQ, company registration number 05675754. Vantage Infrastructure (UK) Limited is authorised and regulated by the Financial Conduct Authority (“FCA”).

Vantage Infrastructure (USA) Inc. registered address; 43rd Floor, 280 Park Avenue, New York, NY 10017, CRD 157458. Vantage Infrastructure (USA) Inc. is a registered investment adviser with the USA Securities and Exchange Commission (please see the relevant Form ADV for further disclosure). Vantage Infrastructure (USA) Inc. relies on the international adviser registration exemption pursuant to section 8.26 of National Instrument 31-103– Registration Requirements, Exemptions and Ongoing Registrant Obligations in the provinces of Alberta, British Colombia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Nunavut, Ontario, Prince Edward Island and Quebec (NRD 61520).

‘Vantage Group’ means the Vantage Infrastructure Group of companies.

About this privacy notice

For the purposes of data protection law, we are a data controller in respect of your personal data. Vantage is responsible for ensuring that it uses your personal data in compliance with applicable data protection law.

The privacy notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.

Personal data that we collect about you

We may collect and process the following personal data about you:

  • Information that you provide to the Vantage group. This includes information about you that you give us by filling in forms or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include your name, address, e-mail address and phone number, information for providing visitor cards and information contained in emails written by you.
  • Information we collect or generate about you. We sometimes record telephone conversations and monitor email communications to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements. The information we capture in this way may include your:
    • name;
    • address;
    • e-mail address and phone number; and
    • identification records.
  • Information we obtain from other sources. We may obtain the following information about you from third parties:
    • identification records and authorised signatory information (from our clients and their investee companies);
    • remuneration information (from our clients’ investee companies); and
    • CVs (from our clients’ investee companies).

Uses of your personal data

Your personal data may be stored and processed by the Vantage Group in the following ways and for the following purposes:

  • to verify your identity as part of our client on-boarding process and to detect and prevent fraud and money laundering; and
  • in order to manage and administer clients’ accounts holdings and to provide our clients with information, products or services they may request from us.

We are entitled to use your personal data in these ways because:

  • we need to in order to perform a contract with you;
  • we have legal and regulatory obligations that we have to discharge;
  • we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
  • we may need to prevent fraud; or
  • the use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as:
    • effectively managing our client relationships; and
    • ensuring the effective surveillance and management of investee companies by our clients.
    • If you agree, we may also contact you about other products and services we think may be of interest to you.

Disclosure of your information to Vantage Group Affiliates and Third Parties

The Vantage Group may disclose your personal data in the circumstances described below:

  • to ensure the delivery of products or services;
  • to ensure the safety and security of our data; and
  • for internal research and statistical analysis purposes.

We will take steps to ensure that the personal data is accessed only by such employees of the Vantage Group that have a need to do so for the purposes described in this notice.

 

We may also share your personal data outside of the Vantage Group:

  • if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
  • to third party agents or contractors (for example, the providers of our electronic data storage services) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice; and
  • 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, establish, exercise or defend our legal rights.

Transfers of personal data outside the UK

The personal data that we collect from you may be transferred to, and stored at, a destination outside the UK. It may also be processed by staff operating outside of the UK who work for the Vantage Group or for one of our suppliers.

Where we transfer your personal data outside the UK, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the UK. This can be done in a number of ways, for instance:

  • the country that we send the data to might be approved as ‘adequate’ by the UK;
  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the UK, obliging them to protect your personal data.  When entering into a new contract, standard contractual clauses must be used in their entirety and without amendment.

In other circumstances, the law may permit us to otherwise transfer your personal data outside the UK. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the UK by contacting us in accordance with the “Contacting us” section below. 

Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • 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

You have a number of legal rights in relation to the personal data that we hold about you. 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 our 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 (other than consent) for doing so;
  • 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 those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  • 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, and the right to 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 continue processing your personal data and/or to refuse that request; and
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the ‘Contacting us’ section below.

You can find out more information about your rights by contacting the Information Commissioner’s Office, or by searching their website at https://ico.org.uk/.

IP Addresses and Cookies

Your data

We do not capture or store any personal data about visitors to our site, unless you communicate with us via the Contact Form, in which case such information is used only for the purposes of communicating with you regarding your query. We will not add you to our mailing list unless you have specifically asked to be added, and we will never share your information with a third party.

Cookies

This website uses Google Analytics for website analytics purposes – meaning that we use them to see how many visitors come to the website, the pages that generate interest and the links that visitors most often click on (amongst other things). Google Analytics uses cookies – small text files that are placed on your computer that store certain limited information about you. The cookies that we use do not enable any website visitor to be individually identified and will only be used for website analytics purposes.

We use two specific types of cookies on this website:

  • Session cookies, which are temporary cookies that remain in the cookie file of your computer until you close your browser (at which point they are deleted).
  • Persistent or stored cookies that remain permanently on the cookie file of your computer.

We also use cookies to confirm that visitors have accepted the Conditions of Use for this website.

Cookies cannot look into your computer and obtain information about you or your family or read any material on your hard drive and, unless you have logged onto an authenticated page, cookies cannot be used to identify who you are. Cookies cannot be used by anyone else who has access to the computer to find out anything about you, other than the fact that someone using the computer has visited a certain website. Cookies do not in any way compromise the security of your computer. Cookies will not be used to contact you for marketing purposes.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

Changes to Privacy Notice

We keep our Privacy Notice under regular review. If we change our Privacy Notice we will post the changes on this page, and place notices on other pages of the website www.vantageinfrastrucuture.com, so that you may be aware of the information we collect and how we use it at all times.

Visitors to our offices

We have security measures in place at our offices, including CCTV and building access controls.

There are signs in our office showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident).  CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).

We require visitors to our offices to sign in at reception and keep a record of visitors for a short period of time.  Our visitor records are securely stored and only accessible on a need to know basis (e.g. to look into an incident).

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to the Compliance Officer, Vantage Infrastructure (UK) Limited, 2nd Floor, 50 St Mary Axe, London, EC3A 8FR, United Kingdom, email: uk.admin@vantageinfra.com.