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POLICY Privacy Policy 1. Who we are VE3 GLOBAL LTD (company number 07343436) is a company registered in England and Wales. Our registered office is 86-90 Paul Street, London, England, EC2A 4NE. In this notice, “VE3”, “we”, “us” and “our” mean VE3 GLOBAL LTD. For the processing covered by this notice, VE3 is normally the data controller. If another VE3 group company is the controller for a particular activity, it will identify itself and provide the relevant privacy information. Privacy contact: dpo@ve3.global 2. Scope of this notice This notice applies where we handle personal information as a controller in connection with: the VE3 website and its contact, enquiry, download and subscription forms; business development, account management and professional communications; webinars, conferences, trade shows and other marketing or industry events; newsletters, research, white papers, invitations and other business marketing; supplier, partner and professional-adviser relationships; and website security, analytics, administration and service improvement. This notice does not replace a client’s privacy notice where VE3 processes personal information only as that client’s processor or sub-processor. It also does not cover employment or recruitment processing, which should be addressed in separate workforce and recruitment privacy notices. 3. Personal information we collect Identity and contact information: name, title, business email address, telephone number, postal address and communication details. Professional information: employer, job title, department, professional interests, qualifications, areas of expertise and public professional profile information. Enquiry and relationship information: the content of enquiries, correspondence, meeting notes, proposals, service interests, customer or supplier relationship information and records of our interactions Event and marketing information:Client services: event registration and attendance, webinar participation, content downloads, newsletter subscriptions, campaign responses and marketing preferences. Technical and usage information:Legal and compliance matters: IP address, device and browser information, operating system, website activity, referral source, date and time of access, log data, cookie identifiers and similar technical information. Security and compliance information: authentication and access records, fraud or security alerts, due-diligence information, sanctions or regulatory checks where relevant, and records needed to comply with law or protect our systems. Transaction and corporate information: information relevant to contracts, invoices, procurement, corporate transactions, disputes or legal claims, where you act for or are connected with an organisation. Preferences and feedback:Transaction and corporate information: communication preferences, survey responses, complaints, feedback and requests made under data protection law. Special-category and criminal-offence information. We do not normally ask you to provide sensitive information through general website or marketing forms. If you provide such information, we will use it only where it is lawful and necessary, and will delete or restrict it when there is no valid reason to retain it. 4. How we obtain personal information Directly from you, including through forms, emails, calls, meetings, event registrations, surveys and contracts. Automatically when you use our website, through server logs, cookies, pixels, tags, scripts and other storage or access technologies. From your employer, a client, supplier, partner, event organiser or another person who introduces you or provides your details for a legitimate business purpose. From public sources, such as corporate websites, professional directories, public registers, tender portals and professional networking platforms. From business-information, data-enrichment, analytics or lead-generation providers, where their collection and disclosure of the information is lawful. From clients where we act as a processor. In that case, the client normally determines the purposes and lawful basis for processing. Where we obtain your information from another source and we are required to provide privacy information directly to you, we will normally do so at our first communication, before disclosing the information to another recipient, or within one month, whichever is required first. 5. How and why we use personal information We use personal information only where we have a lawful basis. The purposes and bases that most commonly apply are set out below. More than one basis may apply to the same activity. Responding to enquiries and providing requested material.Right of access We use your contact details and enquiry information to respond, arrange discussions and provide information you request. The lawful basis is taking steps at your request before entering into a contract, performance of a contract where you are a party, and/or our legitimate interests in communicating with prospective customers and business contacts. Managing customers, suppliers, partners and professional relationships. Right to erasure: We use relationship and professional information to administer contracts, deliver and receive services, manage accounts, maintain records and communicate with relevant contacts. We rely on contract, legal obligations and our legitimate interests in operating our business and managing professional relationships. Running events and webinars. We use registration, attendance and contact information to administer events, provide joining information, manage safety and security, follow up on relevant content and evaluate participation. We rely on contract, consent where required, and our legitimate interests in organising professional events and developing business relationships. Marketing and business development.Running events and webinars. We use contact, professional, preference and engagement information to send relevant business communications and measure their effectiveness. We rely on consent where required by law and, in appropriate business-to-business circumstances, our legitimate interests in promoting our services and maintaining professional relationships. See section 6. Operating and improving the website.Marketing and business development. We use technical, usage and feedback information to provide website functionality, understand use, improve content and user experience, and maintain performance. We rely on consent where required, an applicable exception under the Privacy and Electronic Communications Regulations 2003, and/or our legitimate interests in operating and improving the website. Security, fraud prevention and business continuity. We use technical, access and compliance information to protect our website, systems, personnel, clients and business; investigate incidents; prevent fraud, malware and misuse; and maintain resilience and disaster recovery. We rely on legal obligations and our legitimate interests in maintaining secure and reliable operations. Legal, regulatory and governance purposes. We use and disclose information where necessary to comply with law, respond to regulators or courts, keep required records, conduct audits, enforce agreements, protect rights, manage disputes and establish, exercise or defend legal claims. We rely on legal obligations and our legitimate interests in protecting VE3 and others. Research, reporting and service improvement. We may analyse information to understand market interests, improve our services and prepare internal reports. Where possible, we use aggregated or de-identified information. We rely on our legitimate interests in evaluating and improving our business, subject to appropriate safeguards. Our legitimate interests. These include operating, securing and developing our business; responding to business contacts; maintaining professional relationships; improving our website and services; preventing fraud; and protecting legal rights. Before relying on legitimate interests, we consider the impact on individuals and do not use that basis where your interests, rights or freedoms override ours. 6. Direct marketing We may send business contacts information about VE3 services, research, insights and events where the communication is relevant to their professional role and is permitted by data protection and electronic-marketing law. For corporate subscribers, we may rely on our legitimate interests for UK GDPR purposes and may send electronic business-to-business marketing without consent where the Privacy and Electronic Communications Regulations permit this. For individual subscribers, including sole traders and certain partnerships, we will use consent or a valid “soft opt-in” where required. Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing carried out before withdrawal. Every electronic marketing message will identify VE3 and provide a simple way to unsubscribe or object. We may keep a minimal suppression record after you opt out so that we do not contact you again for the same marketing purpose. You have an absolute right to object to the use of your personal information for direct marketing. To opt out, use the unsubscribe link in a message or contact dpo@ve3.global. 7. Cookies and similar technologies Our website may use cookies, pixels, tags, scripts, local storage and similar technologies that store information on, or access information from, your device. We may use essential or otherwise exempt technologies without consent where they are necessary to provide a service you request, ensure security, remember privacy choices, or another statutory exception applies. Where we rely on the statistical-purposes or functionality exceptions introduced into the Privacy and Electronic Communications Regulations, we will meet the applicable conditions and provide an appropriate way to object where required. We will obtain consent before using non-exempt analytics, advertising, social-media or other tracking technologies. You can accept, reject or change non-essential choices through our cookie banner or preference centre. Our separate Cookie Notice should identify the technologies in use, their providers, purposes and durations. Browser settings may also allow you to delete or block certain technologies, although some website functions may then be unavailable. 8. When providing information is required Where a form or process requires information, required fields will normally be identified. If you do not provide information that is necessary to respond to an enquiry, register you for an event, enter into or perform a contract, verify identity or comply with law, we may be unable to proceed with the relevant request or service. Other information is voluntary. 9. When VE3 acts for a client VE3 sometimes processes personal information as a processor or sub-processor on behalf of a client. In those circumstances: the client or another organisation is normally the controller and decides why the information is used; the client is responsible for identifying the lawful basis and providing the main privacy information; VE3 processes the information under the client’s documented instructions and the applicable data-processing agreement; and if you make a request concerning client-controlled information, we may refer it to the relevant client and assist the client as required by law. 10. Who we share personal information with Where necessary for the purposes described in this notice, we may share information with: VE3 group companies: for internal administration, specialist support, service delivery, security and business development, with the relevant entity acting as controller, joint controller or processor as appropriate. Service providers: including website hosting, cloud infrastructure, disaster recovery, CRM, email, marketing automation, event management, analytics, cookie management, communications, cyber-security, IT support and document-management providers. Clients, suppliers, partners and event organisers: where necessary to manage the relevant relationship or activity and where the sharing is expected, disclosed or otherwise lawful. Authorities and other lawful recipients: including courts, regulators, law-enforcement bodies, public authorities and parties to legal proceedings where disclosure is required or permitted by law. Transaction counterparties: including prospective investors, buyers, sellers, lenders and their advisers in connection with a financing, reorganisation, merger, acquisition, insolvency or sale of assets. Other parties needed to protect rights and security: where reasonably necessary to prevent fraud, malware, spam, misuse or harm, or to establish, exercise or defend legal rights. We require service providers to protect personal information, keep it confidential and process it only for authorised purposes. We do not permit them to use it for their own unrelated purposes unless they separately act as a controller and provide the required privacy information. 11. International transfers Because VE3 operates internationally and uses global service providers, personal information may be accessed or transferred outside the United Kingdom, including to countries in which VE3 group companies, clients or suppliers operate. Where UK data protection law restricts a transfer, we use an approved transfer mechanism, such as: UK adequacy regulations; the UK International Data Transfer Agreement or the UK Addendum to the European Commission’s Standard Contractual Clauses; binding corporate rules or another approved safeguard; or a specific legal exception where it is appropriate and lawful. Where appropriate safeguards are used, we carry out the required transfer assessment and adopt supplementary protections where necessary. You may contact dpo@ve3.global for further information about the relevant safeguards or to request a copy, subject to appropriate redactions. 12. How long we keep personal information We keep personal information only for as long as it is reasonably needed for the purpose for which it was collected, to comply with legal, accounting or reporting requirements, or to establish, exercise or defend legal claims. Our standard retention approach is: Enquiries and prospective business contacts: normally up to 24 months after the last meaningful interaction, unless the relationship becomes active or a longer period is justified. Marketing records: until you opt out, consent is withdrawn, or there has been 24 months of inactivity; a minimal suppression record may be retained for as long as reasonably needed to respect the opt-out. Event and webinar records: normally up to 24 months after the event, unless needed for an active relationship or legal purpose. Customer, supplier and partner relationship records: for the relationship and normally seven years afterwards, subject to the nature of the record and legal requirements. Website and security logs: normally up to 12 months, unless required for an incident, investigation, legal claim or longer security purpose. Cookie and analytics information: for the periods stated in the Cookie Notice or preference centre and no longer than necessary for the stated purpose. Consent, rights-request and complaint records: normally six years after the relevant consent ends or the matter is closed, to demonstrate compliance and manage potential claims. Legal claims and investigations: for as long as the matter remains active and for the applicable limitation or regulatory period afterwards. We may shorten or extend these periods where appropriate, including where information is anonymised, a legal hold applies, a regulator requires retention, or deletion is necessary to comply with law. When information is no longer required, we delete it, anonymise it or securely restrict its use. 13. Security We use appropriate technical and organisational measures designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. Measures may include access controls, authentication, encryption, logging, backup, vulnerability management, staff training, contractual controls and incident-response procedures. No method of transmission or storage is completely secure. If a personal-data breach occurs, we will assess it and notify affected individuals and the Information Commissioner’s Office where the law requires. 14. Your data protection rights Subject to the conditions and exemptions in applicable law, you may have the right to: Be informed: about how we collect and use your personal information. Access: your personal information and obtain a copy. Rectification: of inaccurate or incomplete information. Erasure: of personal information where there is no lawful reason to continue using it. Restriction: of processing in specified circumstances. Data portability: for certain information you provided to us where processing is automated and based on consent or contract. Object: to processing based on legitimate interests, and to object at any time to direct marketing. Withdraw consent: at any time where we rely on consent. Safeguards relating to significant automated decisions: including information, human intervention and an opportunity to make representations or challenge a decision where applicable. Complain: to VE3 and to the Information Commissioner’s Office or another competent supervisory authority. To exercise a right, email dpo@ve3.global and describe your request. We may ask for information reasonably necessary to verify your identity, locate the relevant information or confirm that you are authorised to act for another person. We normally respond without undue delay and within one month after receiving the request and any information reasonably required to verify identity. We may extend the period by up to two further months where permitted because the request is complex or numerous, and will explain any extension. We do not normally charge a fee, but the law permits a reasonable fee or refusal in limited circumstances. 15. Data protection complaints You may complain to us if you believe we have not handled your personal information properly. Email dpo@ve3.global with the subject line “Data protection complaint”, or use any electronic complaint form made available on our website. We will provide a clear way to complain, acknowledge a data protection complaint within 30 days, take appropriate steps to investigate it, keep you informed where appropriate and communicate the outcome without undue delay. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority. You can find its contact and complaint details on the ICO website. You do not have to complain to VE3 before contacting the ICO, although raising the matter with us first may allow us to resolve it. 16. Automated decision-making and profiling We do not currently use personal information covered by this website and business-contact notice to make decisions based solely on automated processing that produce legal or similarly significant effects. We may use limited analytics or segmentation to understand website and marketing engagement, but not to make such significant decisions. If this changes, we will update this notice and provide meaningful information about the logic involved, the significance and likely consequences of the processing, and the safeguards available to you. 17. Children Our website and services are intended for business and professional audiences and are not directed at children. We do not knowingly seek personal information from children through general website or marketing activities. If you believe a child has provided information to us inappropriately, contact dpo@ve3.global. 18. Other jurisdictions Additional or different privacy rights may apply outside the United Kingdom. Where applicable law requires a jurisdiction-specific notice or supplement, VE3 will provide it separately. This notice should not be read as limiting any mandatory rights available under local law. 19. Changes to this notice We may update this notice to reflect changes in our services, technology, suppliers, legal requirements or processing activities. We will publish the updated version on our website and change the “Last updated” date. Where a change materially affects how we use personal information, we will provide additional notice where appropriate. 20. Contact us Privacy contact: dpo@ve3.global Controller: VE3 GLOBAL LTD Company number: 07343436 Registered office: 86-90 Paul Street, London, England, EC2A 4NE Ready to transform your data? Let's discuss how our data analytics expertise can drive growth and innovation for your business. Let’s Connect ➝ Innovating Ideas. 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