Privacy Statement

1. Our approach to privacy

Vane Finance Technology Ltd ("Vane", "we", "our", or "us") is committed to protecting and respecting your privacy.

This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies as a result of you using our website at www.vane.capital (the "Site").

Vane Finance Technology Ltd. is the data controller of the personal information we hold about you.

2. Personal information we collect about you and how we use it

We collect personal information that you voluntarily submit directly to us when you use our Site. This can include information you provide to us when you register for an account and user profile, correspond with us or use some other feature of our Site.

We may also collect personal information from third parties, such as social networks.

We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Site. If you choose not to provide such personal information, we may not be able to provide access to certain aspects of the Site to you or respond to your other requests.

We also automatically collect personal information indirectly about how you access and use the Site and information about the device you use to access the Site.

The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of the personal information.

We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

3. Anonymous data

We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Site and developing new products and features. We may also share such anonymised information with others.

4. Data retention

We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 in accordance with our legal obligations and legitimate business interests.

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

5. Recipients of personal information

We may also share your personal information with the following (as required in accordance with the uses set out in Annex 1 and Annex 2 ):

  1. Site providers and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing mailing, email, advertising or chat services, fraud prevention, web hosting, or providing analytic services.
  2. Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.
  3. Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of Vane, its users or others.
  4. Other members of the Vane group: we may share your personal information with our affiliates (for example, where they provide services on our behalf) or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1 .
6. Marketing and advertising

From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on your products and services.

Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

We will only send you marketing messages if you have given us your consent to do so, unless consent is not required under applicable law (e.g. in certain circumstances where we have a pre-existing customer relationship your consent is not required). You can withdraw your consent or opt out of receiving further communications at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.

We may also ask third parties to send you messages asking for your feedback on our behalf. If you give us permission to do so, we may share your contact details with such parties for this purpose.

7. Storing and transferring your personal information

Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations. If you are located in the UK or European Union ("EU"), your personal information may be processed outside of the UK and EU including in the United States; these international transfers of your personal information will be made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy policy.

8. Your rights in respect of your personal information

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

  • Right of access. You have the right to obtain access to your personal information.
    Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
  • Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
  • Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
  • Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
  • Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent.
  • You also have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit some of the personal information you have submitted to us by logging into your account on our website.

You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

9. Cookies and similar technologies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. The specific cookies we use are set out in Annex 2 .

Cookies are pieces of code that allow for personalisation of our website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your computer's hard disk for record-keeping purposes.

We use the following types of cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Site and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Advertising/targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it or other sites more relevant to your interests or serve you our advertisements when you visit third party sites. We may also share this information with third parties who provide a service to us for this purpose.
  • Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on our website. These third parties are responsible for setting out their own cookie and privacy policies.

The cookies we use are designed to help you get the most from the Site but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.

  • Cookie settings in Internet Explorer
  • Cookie settings in Firefox
  • Cookie settings in Chrome
  • Cookie settings in Safari web and iOS.

If you would like to find out more about cookies and other similar technologies, please visit www.allaboutcookies.org or the Network Advertising Initiative's online sources at www.networkadvertising.org.

10. Interest based advertising

We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. To do this, we or our advertising partners may collect information about how you use or connect to our Site, or the types of other websites, social media services, content and ads that you (or others using your device) visit or view or connect to our Site so that we or our advertising partners may play or display ads on our Site, on other websites, apps or services you may use, and on other devices you may use.

Typically, but not always, this information is collected through cookies and similar tracking technologies. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

To learn about interest-based advertising and how you may be able to opt-out of some of this advertising and to limit some third party advertising cookies, you may wish to visit:

Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.

11. Links to third party sites

Our Site may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

12. Our policy towards children

Our Site is not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

13. Changes to this policy

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

14. Notice to you

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Site. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

15. Contacting us

Please contact hello@vane.capital if you have any questions, comments and requests regarding this Privacy Policy.

This privacy policy was last modified on the 27 August 2020.

Annex 1 – Personal information we collect

 

Category of personal information 

Contact details (name, business, email, phone number)

 

How we use it and Legal basis for processing

  • Provision of services on the Site
  • Administration of Account

Such processing is necessary for performance of a contract and to take steps prior to entering into a contract.

  • Marketing and Advertising 

Either consent (if required under applicable law) or our legitimate interests, namely marketing and advertising to our contacts and customers.

  • To communicate with you regarding changes to our policies, other terms and other administrative information such as reminders, technical notices, updates and security alerts.

Such processing is necessary for our legitimate interests, namely to ensure you are aware of any changes to our policies, terms and other such technical updates. 

 

Category of personal information 

Technical information (IP address, browser type, internet service provider, device identifier, your login information, time zone setting, browser plug-in types and versions, preferred language, activities, operating system and platform, and geographical location) 

 

How we use it and Legal basis for processing

  • Analytics
  • Improve the Site to ensure that content is presented in the most effective manner for you
  • Marketing and Advertising
  • To ascertain your preferences

 Consent 

 

Category of personal information

Usage data (clickstream to, through and from the Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs), date and time pages are accessed, and website navigation and search terms used) 

 

How we use it and Legal basis for processing

  • Analytics
  • Improve the Site to ensure that content is presented in the most effective manner for you
  • Marketing and Advertising
  • To ascertain your preferences

 Consent

Annex 2 - Cookies

 
Cookie name 
cookiesAccepted

Type (session or persistent) 
Persistent

Source (first or third party) 
First party

Purpose 
Records users’ acceptance of the privacy policy

 

Cookie name 
_billfront_webapp_session

Type (session or persistent) 
session

Source (first or third party) 
First party

Purpose 
For login authentication.

 

Cookie name 
remember_customer_token

Type (session or persistent) 
Persistent

Source (first or third party) 
First party

Purpose 
Remembers the user to login for the next visit

 

Cookie name
_ga

Type (session or persistent) 
Persistent

Source (first or third party) 
Third party

Purpose 
We use Google Analytics to analyse and improve the Site based on user behaviour. The information is all anonymous and includes the number of visitors to the Sites, where visitors have come to the Sites from and the pages they have visited.

Read Google's overview of privacy and safeguarding data here


Cookie name 
Google AdWords cookie

Type (session or persistent) 
Persistent

Source (first or third party) 
Third party

Purpose 
We use GoogleAds conversion tracking to record and analyse customer actions (such as clicking on an ad, page views, downloads).


Cookie name 
Facebook pixels

Type (session or persistent) 
Persistent

Source (first or third party) 
Third party

Purpose 
A Facebook Pixel is a piece of code we place on the Site. We use this to analyse the activity of Facebook visitors on the Site. We may also use this data to display relevant ads to you on Facebook and to monitor the effectiveness of Facebook ads. You can manage your preferences in your Facebook account and/or your Internet browser.

Read about Facebook's data practices here

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Offices

Vane GmbH
Marienburger Str. 1
10405 Berlin
Germany

Vane Finance Technology Ltd.
1 Poultry
London EC2R 8EJ
United Kingdom

Vane Finance Technology Inc.
41 Madison, 31st Floor
New York, NY 10010
USA

Vane Finance Technology Limited is a company registered in England and Wales (Company No: 9446187) and is registered in the UK with the Financial Conduct Authority reference 09446187. Vane Finance Technology Inc. is registered in the State of Delaware and operates under a California Financing Law license. Our Headquarters is Vane GmbH (HBR 162057 B), registered in Berlin, Germany.

Copyright © 2021 Vane (Group). All Rights Reserved.