Privacy Policy

Introduction

This privacy policy tells you what to expect us to do with your personal information.

Verne is committed to respecting your online privacy and the company recognises your need for appropriate protection and management of any personally identifiable information (personal information) that you share with us. Personal information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect and retain your personal information as a user of our website or as a customer (or representative of a customer). Should you have any specific questions regarding this policy, or how we store or use your data, please do not hesitate to contact us at privacy@verneglobal.com.

This privacy policy is based on the requirements contained in the UK General Data Protection Regulation (the UK GDPR) and Regulation (EU) 2016/679 of the European Parliament and of the Council (the EU GDPR), together with applicable national legislation implementing or supplementing the foregoing in the jurisdictions in which Verne is established.

Contact Details

We can be contacted as follows:

Email: privacy@verneglobal.com

Address:

In the UK, or where Jules I Limited or Volta Data Centres Limites acts as controller : 36-43 Great Sutton Street, London, United Kingdom, EC1V 0AB

In Iceland, or where Verne Global ehf. acts as controller: Valhallarbraut 868 262, Reykjanesbaer, Iceland

In Finland, where Ficolo Oy acts as controller: Mittalinja 1, FI-01260, Vantaa, Finland

What information we collect, use, and why

We collect or use the following information to provide our services to you / your business:

• Names and contact details
• Addresses
• Payment details (including card or bank information for transfers and direct debits) if you purchase a service from us.
• Credit reference information
• Account information
• Identification documents

We collect or use the following information if you visit our website:

• Website user information (including user journeys and cookie tracking)

We collect or use the following information for the operation of customer accounts:

• Names and contact details
• Addresses
• Payment details (including card or bank information for transfers and direct debits)
• Account information, including registration details

We collect or use the following information for marketing purposes:

• Names and contact details
• Addresses
• Marketing preferences
• Location data (at country level)
• Website and app user journey information
• Records of consent, where appropriate

Website Analytics

Verne also monitors its website user visitors, traffic, flow and browsing statistics via Google Analytics, Albacross and Microsoft Clarity.

These analytics service providers collect information through our use of their services on our website. They use this information, including IP addresses and information from cookies, for several purposes, such as improving their respective analytics services. Information is shared with analytics service providers on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/. To find out similar information on Albacross, please see the following page: https://www.albacross.com/privacy-policy, and on Microsoft Clarity, please see https://clarity.microsoft.com/privacy.

Lawful bases

To the extent relevant, we will use the personal information we collect from you for the following purposes based on the following lawful bases:

Where we get personal information from

We obtain personal information directly from you. We collect information from you when you register for a newsletter or submit an online enquiry form on our website and, in respect of the use of cookies, we may undertake some processing when you visit our website.

How long we keep information

We will retain your personal information for no longer than necessary. When determining the relevant retention periods, we take into account factors including:

• the purpose(s) and use of your information;
• whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
• whether the personal information can be kept up to date and accurate;
• any relevant surrounding circumstances (such as the nature and status of our relationship with you);
• any relevant limitation periods under applicable law, for example, in respect of contract claims;
• disputes or investigations (potential or actual); and
• guidance issued by relevant data protection authorities.

If you require further information, please contact us using the contact details provided above.

Others we may share personal information with

We may share your personal information with third parties from time to time, including:

• professional advisers, such as accountants, financial advisers and lawyers, where they require the information in order to advise Verne;
• authorities with responsibility for tax, customs, visas and immigration, and any other regulatory authority which may require information from Verne under applicable law;
• competent authorities, to indicate possible criminal acts or threats to public security;
• insurers, where such processing is necessary in relation to a claim (or potential claim) that Verne receives;
• prospective or actual purchasers or sellers (and their professional advisers) in the context of a business or asset sale or acquisition by us, a merger or similar business combination event, whether actual or potential;
• our service providers, to the extent necessary for them to be able to provide the relevant services to Verne; and
• independent contractors, which we use occasionally in our business and, in such cases, your information will be shared with independent contractors only where it is necessary for them to perform the function we have hired them to perform in relation to our business.

Sharing information outside the UK

In certain circumstances, we may transfer your information (which does not include any customer data hosted as part of our services to you) outside of the United Kingdom (“UK”) and/or the European Economic Area (“EEA”). Where we do so, we will ensure that either the transfer is to a territory subject to an adequacy finding (as a matter of UK and/or European Union (“EU”) law, as applicable) or that appropriate safeguards are in place, including, for example, that standard contractual clauses together with any supplementary measures required are in place for the transfer of your information outside the UK and/or EEA. For example, we may transfer personal information from Finland and/or Iceland to the UK through reliance on the European Commission’s adequacy decision in respect of the UK; and we may transfer personal information from the UK to Finland and/or Iceland through reliance on UK adequacy regulations in respect of the EEA.

Your data protection rights

Under data protection law, you have rights including:

• • • • Right to information: You have the right to be provided with clear, transparent and easily understandable information about how your personal information is processed. (This is contained in this privacy policy.) For further information, please contact us using the contact details above.
      • Right to access: You have the right to obtain access to your personal information (if we are processing it), and certain other information (similar to that provided in this privacy policy). You also have the right, subject to certain exceptions, to obtain a copy of your personal information which we process.
      • Right to rectification: You are entitled to have your information corrected if it is inaccurate or incomplete.
      • Right to erasure: In certain circumstances you can request for your personal information to be erased from our records. This is not a general right to erasure; there are exceptions.
      • Right to restrict processing: You have rights to 'block' or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further.
      • Right to object to processing: You have the right to object to certain types of processing, in certain circumstances. In particular, you have the right to object to the processing of your personal information based on legitimate interests grounds.
      • Right to data portability: You have the right to obtain and reuse your personal data in a structured, commonly used and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.
      • Right to withdraw consent: If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful).
      • Right to Complain: You also have the right to lodge a complaint with a data protection authority (although we would always encourage anyone to bring any concerns to our attention first, so that we can try to resolve them).

The rights set out above are not absolute. Applicable laws may, for example, require us to decline a request. Alternatively, a request may be refused if an exception exists in law, for example, to protect the rights of other parties.
To make a data subject rights request, please contact us using the contact details at the top of this privacy policy.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy policy.