PRIVACY POLICY

This is V-Nova’s general privacy policy which sets out how V-Nova collects, stores and uses your personal data. V-Nova is committed to respecting your privacy. We take privacy, security, and complying with data protection laws seriously.

1. WHO IS RESPONSIBLE FOR YOUR DATA

This privacy notice is issued on behalf of the V-Nova Group so when we mention V-Nova, “we”, “us” or “our” in this privacy notice, we are referring to the relevant V-Nova company in the V-Nova Group responsible for processing your data. V-Nova Limited is the controller and responsible for the website www.v-nova.com. V-Nova Limited is a company registered in England and Wales under company number 11125008.

2. WHAT DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

You may interact with V-Nova in a number of ways, for example, by browsing our website, becoming a customer of V-Nova, becoming a supplier of V-Nova, applying for a job with V-Nova or becoming an investor in V-Nova. Depending on how you interact with us, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, last name, title, date of birth.

Contact Data includes address, billing address, delivery address, email address and telephone numbers.

Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

Transaction Data includes details about payments to and from you, details of products and services purchased by you or supplied to us by you or by your employer where you have been involved in such transaction as their key personnel.

Recruitment Data includes recruitment information, completed application forms, copies of right to work documentation, references, employment history and other information included in a CV or cover letter or as part of the application process.

Financial Data includes bank account details (to be clear, we only process your Financial Data where you have specifically provided it to us).

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW WE COLLECT YOUR PERSONAL DATA

We mainly collect personal data about you when you give it to us voluntarily. However, we may also collect it from other sources if it is legal to do so. The different methods we use to collect data from and about you are:

Direct interactions. You may, for example, give us your Identity, Contact, Profile, Marketing and Communications, and Financial Data by filling in forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal data you provide when you:

• Order our products or services directly or on behalf of your employer;
• Provide us with products or services directly or on behalf of your employer;
• Subscribe to our publications;
• Request marketing to be sent to you;
• Fill in a form to download our whitepapers or other documents on our website:
• Enter a competition, promotion or survey;
• Attend one of our events or visit us at a trade show;
• Give us some feedback;
• Make an enquiry;
• Invest in V-Nova; or
• Apply for a job with V-Nova.

Automated technologies or interactions. If you are simply browsing our website, we will not collect any information which will identify you by name. However, as you browse and interact with our website, we may automatically collect Usage and Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Third parties or publicly available sources. We may receive Technical, Recruitment and Identity Data about you from various third parties and public sources as set out below:

• Analytics providers such as Google.
• Publicly availably sources such as Companies House and LinkedIn.
• From our resellers, referrers, introducers and recruiters.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of a contract: where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate interest:means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Comply with a legal obligation: where it is necessary to process your personal data to comply with a legal obligation that we are subject to, including for example accounting and tax requirements.

5. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

6. MARKETING

You may receive marketing communications from us if you have requested information from us, purchased goods or services from us or if you provided us with your details when you filled out a form on the website, entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing, and it is not otherwise prohibited by law.

We will not share your personal data with anyone outside the V-Nova group of companies for them to use for their own purposes, such as marketing their products and services, or the products and services of another third party, without your express, opt-in consent.

You can ask us to stop sending you marketing messages at any time by following the opt-out/unsubscribe links on any marketing message sent to you or by contacting us at any time.

7. COOKIES

We collect information automatically through the use of “cookies”. A cookie is a text file containing small amounts of information that a website can send to your browser, which may then be stored on your computer as an anonymous tag that identifies your computer but not you. Some of our Website pages use cookies, to better serve you when you return to the Website. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies; however, if you do this, some of our Website may not work properly.

For information about the specific cookies used on this Website, please see below:

8. SHARING YOUR PERSONAL DATA

We may have to share your data with third parties, including third-parties who provide services to us and other entities in the V-Nova group. We will only share your personal data with third parties where required by law, where it is necessary to administer the relationship with you or where we have another legitimate interest in doing so and our interests are not overridden by the impact on you. Third parties will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure. All our third-party service providers and other entities in the group are required to take appropriate security measures to protect your personal data in line with our policies and as required by law.

We will only send data outside of the European Economic Area (‘EEA’) to work with our agents and advisers who deliver services to us or to comply with a legal duty. If we do transfer data outside the EEA, we will make sure that it is protected in the same way as if it were being used in the EEA. We will use one of the following safeguards to ensure that it is protected:

• Transfer the data to a non-EEA country which has privacy laws at least as protective as those within the EEA
• Put in place a contract with the recipient of the data which means the recipient must protect the data to the same standards as required within the EEA, or
• Transfer it to organisations which are part of the Privacy Shield. The Privacy Shield is a framework which sets out the standards for data to be sent between the United States and European countries. The Privacy Shield ensures that data is protected to the same standards as used within the EEA.

9. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a genuine business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 requirements.

If you apply for a job with us, we will retain your information for the period we are considering your application, and may also retain some of your information for a reasonable period for purposes of considering you for future positions.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. You will not normally have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive (provided we are allowed to charge a fee by law). Alternatively, we may refuse to comply with your request in these circumstances (provided we are allowed to do so by law).
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

13. PERSONS UNDER 18 YEARS OF AGE

The website www.v-nova.com, and the V-Nova business, is not intended for people under 18 years of age. We do not knowingly collect data from people under 18. If you become aware that your child has provided us with personal data without your consent, please contact us. If we become aware that a person under 18 has provided us with personal data we take steps to remove that information and terminate the applicable account.

14. CONTACT

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the Office Manager by email on info@v-nova.com or by post to Level 2, 20 Eastbourne Terrace, Paddington, London, England, W2 6LG. We hope that we can resolve any query or concern you raise about our use of your personal data.

You also have the right to make a complaint at any time with a supervisory authority where you work, normally live, or where any alleged infringement of data protection laws occurred. The UK supervisory authority for data protection issues is the Information Commissioner’s Office (ICO) (www.ico.org.uk).

This version was last updated on 03 May 2022. We reserve the right to make changes to this privacy policy at any time, and such changes will take effect as soon as they are posted on our website, so please review this Privacy Policy frequently.