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PRIVACY POLICY

VASUDA UK LIMITED and VASUDA EUROPE UAB (“we”, “us”, or “our”) recognise and value the trust that you place in us when interacting with us. This privacy policy (the “Privacy Policy”) explains how we use your Personal Data, as defined in section 2 below, describes the categories of Personal Data we process and for what purposes and explains your data protection rights and how to exercise them.

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VASUDA UK LIMITED is established in the United Kingdom (“UK”) but operates as a global business, it is subject to (i) the UK General Data Protection Regulation, as supplemented by the Data Protection Act 2018 and (ii) the EU General Data Protection Regulation. 

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VASUDA EUROPE UAB is established in Lithuania but operates as a global business, it is subject to (i) the UK General Data Protection Regulation, as supplemented by the Data Protection Act 2018 and (ii) the EU General Data Protection Regulation. 

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We take your privacy seriously and we are committed to collecting and using your Personal Data fairly and in accordance with the requirements of applicable data protection legislation.

 

1. Important information and who we are
Depending on the VASUDA entity you are facing, VASUDA UK LIMITED will be the data controller of, and will be responsible for, your Personal Data.

  • VASUDA UK LIMITED is a private limited company incorporated under the laws of England and Wales. 

  • VASUDA EUROPE UAB is a limited liability private exempt company incorporated under the laws of Lithuania.

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If you have any questions about this Privacy Policy or our data protection practices, please contact us by emailing privacy@vasudainternational.com or by courier at the appropriate postal address.

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2. The data we collect about you

  • “Personal Data” means any information relating to an identified or identifiable natural person.  We may collect, use, store, transfer or otherwise process different kinds of Personal Data about you, as follows:

  • Identity data including your name, date of birth, place of birth, gender, nationality, copies of your identity card, passport and/or driving licence, and, where offered to us, data relating to your family, education and employment background.

  • Contact data including your billing/registered/residential address, email address and telephone number.m you are an employee or other staff member), information about any shareholdings, business contact details.

  • Client-related data including business information, relationship with you (or with a client of whom you are an employee or other staff member), information about any shareholdings, business contact details.

  • Financial data including your bank account details, your tax status information, your tax identification number and your fiscal residence.

  • Other background identification data including evidence of beneficial ownership and source of funds to comply with our client due diligence, know your customer (“KYC”) and anti-money laundering regulations and collected as part of our client acceptance and ongoing monitoring procedures as required by law.

  • Usage data including data obtained through your use of our website or any electronic system or interface that we provide to you through our website (the “Online Platform”) as well as data collected through cookies, server logs and other similar tracking technologies.

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​We may process your special category personal data if:

  • we have your explicit consent; or

  • the processing is necessary for reasons of substantial public interest, on the basis of UK law or Union or Member State law, for example to comply with KYC and anti-money laundering regulations.

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We may collect data relating to criminal convictions and offences subject to compliance with the strict conditions set out under the applicable data protection legislation.

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We digitally record all telephone conversations.

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3. How is your personal data collected?
We use different methods to collect Personal Data from and about you including through:

  • direct interactions with you. In those cases, it is your responsibility to ensure that all such Personal Data is complete in all material respects and not misleading;

  • publications/databases made available by official authorities;

  • our corporate clients, prospects, or service providers;

  • websites/social media pages containing information made public by you (e.g. your own website or social media);

  • databases made publicly available by third parties; and

  • automated technologies or interactions, for example through your use of our website or Online Platform. We collect this Personal Data by using cookies, server logs and other similar tracking technologies. Please see our Cookie Policy for further details.

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We may also collect information about you even if you do not have a direct relationship with us. This may for example happen when your contact details are provided to us by one of our clients, prospects and if you are (by way of example and without limitation) a legal representative, an ultimate beneficial owner, a shareholder, an employee or a staff member of that client or prospect.

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4. How we use your personal data
We will only use your Personal Data for the following purposes:

  • To provide foreign exchange services, payment services and related services to you (or to a client of whom you are an employee or other staff member), which includes providing you with information regarding our services, assisting you and answering your requests and having proof of transactions;

  • to discharge our legal and regulatory obligations, e.g. to prevent and respond to actual or potential fraud or illegal activities according to KYC and anti-money laundering regulations ;

  • to establish, exercise or defend our legal rights or for the purpose of legal proceedings;

  • to record and monitor your use of our website, or our Online Platform or our other online services for our business purposes which may include analysis of usage, measurement of site performance and generation of marketing reports;

  • in the event that we buy or sell any business or assets, or substantially all of our assets are acquired by a third party, we may share your Personal Data to the prospective buyer, and in the event of an acquisition, Personal Data held by us about our clients will be one of the transferred assets;

  • to engage in marketing and business development activity in relation to our services, including to undertake business/market research, survey and analysis;

  • for managing the operation of our website, our Online Platform and our business;

  • to look into any complaints or queries you may have.

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In addition, we will only process your Personal Data where we have a lawful basis for doing so. Our lawful basis will be one or more of the following:

  • Consent – insofar as you have given us your consent for the processing of Personal Data, such consent will serve as a legal basis for the processing; You can withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. I Where we are also processing your Personal Data based on a different legal basis – to perform a contract, for example – your withdrawal of consent will not affect that additional processing.

  • Performance of a contract or processing of a payment instruction – we may need to collect and use your Personal Data for the performance of a contract to which you are party or in order to take steps at your request prior to entering a contract or to process a payment instruction from you.

  • Legitimate interests – we may use your Personal Data as is necessary for the purposes of pursuing our legitimate interests (this includes carrying out the business of providing foreign exchange services, payment services and related services and pursuing our general business interests) where your interests and fundamental rights do not override those interests.

  • Compliance with our legal obligations – we may use your Personal Data as necessary to comply with applicable law and regulations, including to comply with our client due diligence, KYC and anti-money laundering regulations.

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Where we need to collect, or you are required to provide, Personal Data by law or applicable regulations or under the terms of a contract we have with you and you fail to provide the Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to decline to provide or receive the relevant services, but we will notify you if this is the case at the time the Personal Data is collected.

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5. Disclosures of your personal data
In providing services to our clients and in complying with our legal obligations, we may share your Personal Data, insofar as we are permitted by applicable data protection legislation to do so, with the following recipients:

  • third party agents/suppliers or contractors, bound by obligations of confidentiality, in connection with the processing of your Personal Data for the purposes described in this Privacy Policy. This may include, but is not limited to, IT service providers such as cloud providers of software as a service, data room providers and providers of our IT servers and communications service providers; and our professional advisors (legal, auditing or other special services provided by lawyers, notaries, trustees, company auditors or other professional advisors);

  • third parties relevant to the services that we provide. This may include, but is not limited to, counterparties to transactions, other professional service providers, financial institutions, regulators, authorities, governmental institutions and stock exchanges; and/or

  • to the extent required by law, regulation or court order, for example, if we are under a duty to disclose your Personal Data in order to comply with any legal obligation.

 

The recipients referred to above may be located outside the jurisdiction in which you are located or in which Vasuda International provides the services. See the section on “Sending Personal Data outside the UK and the EEA” below for more information.

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6. Sending personal data outside the UK and the EEA
We may need to transfer your Personal Data to a country outside the UK or outside the European Economic Area (the “EEA”), such country being referred to as a “third country”.

Where this is the case, we will make sure that your Personal Data is protected to the same extent as in the UK and the EEA by implementing one of the following measures:

  • we will transfer Personal Data to a third country with privacy laws that give the same level of data protection as in the UK and EEA, as evidenced by (i) “adequacy regulations” made by the Secretary of State (in case of a transfer outside the UK) or (ii) an “adequacy decision” adopted by the European Commission (in case of a transfer outside the EEA);

  • in the absence of adequacy regulations or of an adequacy decision (as applicable), we will put in place appropriate safeguards such as (i) standard contracts for international transfers of Personal Data approved for use by the UK Information Commissioner’s Office (in case of a transfer outside the UK) or (ii) standard contractual clauses approved for use by the European Commission (in case of a transfer outside the EEA


7. Personal data retention
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.

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We may retain your Personal Data for a longer period (i) to comply with our record retention requirements under applicable law and regulations, (ii) to defend or bring any existing or potential legal claims, (iii) to deal with any future complaints regarding the services we provided and (iv) to maintain business records for analysis and/or audit purposes.

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To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

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8. Your legal rights
In accordance with the applicable data protection legislation, and within the limits thereof, you have, in relation to your Personal Data, the following rights:

  • Right of access: you can ask us to provide you with a copy of the Personal Data that we hold about you.

  • Right to rectification: if you believe any of your Personal Data is incorrect or incomplete, we will, upon your request, take steps to check it and correct any factual inaccuracies.

  • Right to erasure: you can ask us to delete, remove, or stop using your Personal Data if there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).

  • Right to restriction of processing: under certain circumstances, you may ask us to restrict the processing of your Personal Data.

  • Right to object to processing: under certain circumstance, you can object to us keeping or using your Personal Data.

  • Right to data portability: if we hold your Personal Data electronically, you can ask us to transfer the data to another organisation in a safe and secure way and in a machine readable format.

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If you wish to exercise any of the rights set out above, or you wish to withdraw your consent to our processing of your Personal Data, please contact us by emailing privacy@vasudainternational.com

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We are committed to working with you to achieve a fair resolution of any complaint or concern about your privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right:

  • in relation to VASUDA UK LIMITED: to make a complaint at any time to the Information Commissioner’s Office, the UK data protection authority (www.ico.org.uk);

  • in relation to VASUDA EUROPE UAB: to make a complaint at any time to the Office of the Information and Data Protection Commissioner, or to your national Data Protection Authority, if you are located in the EEA (Our Members | European Data Protection Board (europa.eu)).


9. Cookies
We may use cookies and other similar tracking technologies on our website and Online Platform. Cookies are small text files that may be stored on your computer or mobile device when you visit a website. These technologies may do different things, such as letting you navigate between web pages efficiently and remembering your preferences. To find out more about how we use cookies and email tracking, please see our Cookie Policy.

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10. How is this Privacy Policy modified?
This Privacy Policy may change from time to time, and we shall take all reasonable steps to inform you in such a case, in particular by publication on our website, which we encourage you to consult regularly.

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