Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity on our website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our website. The technologies we use may include:

• Cookies or Browser Cookies: A cookie is a small file placed on Your Device. You can instruct your browser to refuse all Cookies or to indicate when a cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of Our website. Unless you have adjusted Your browser setting so that it will refuse Cookies, Our website may use Cookies.
• Flash Cookies: Certain features of Our website may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on Our website. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.
• Web Beacons: Certain sections of Our website and Our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These cookies are essential to provide You with services available through the website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the website.

Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These cookies allow us to remember choices You make when You use the website, such as remembering Your login details or language preference. The purpose of these cookies is to provide You with a more personal experience and to avoid You having to re-enter Your preferences every time You use the website.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our website, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You.

Personally identifiable information (PII) may include, but is not limited to:

• Email address
• Usage data
• Link or proof of the visitor’s professional investor status

Usage Data

Usage Data is collected automatically when using the website.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of Our website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the website by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our website or when You access the website by or through a mobile device.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain Our website, including monitoring the usage of Our website.
• To manage Your Account: to manage Your registration as a user of the website. The Personal Data You provide can give You access to different functionalities of the website that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the website.
• To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.
• To manage Your requests: To attend and manage Your requests to Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about Our website users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of Our promotional campaigns and evaluating and improving Our website, products, services, marketing and Your experience.

We may share Your personal information in the following situations:

• With Website Providers: We may share Your personal information with Website Providers to monitor and analyse the use of Our website, to contact You. Some of Our Website Providers may be located outside the United Kingdom and may be subject to different Data Protection law.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company. Some of Our business transfers may take place to locations outside the United Kingdom and may be subject to different Data Protection law.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honour this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us. Some of Our Business Affiliates may be located outside the United Kingdom and may be subject to different Data Protection law.
• With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions. Some of Our business partners may be located outside the United Kingdom and may be subject to different Data Protection law.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.
• As required by law or regulation: There may be situations where law or regulation requires us to share Your data with appropriate authorities.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our legal obligations (for example, if we are required to retain Your data to comply with applicable laws), resolve disputes, and enforce Our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our website, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other personal information.

Some transfers of Your personal data may be made to locations outside the United Kingdom and may be subject to different Data Protection law.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the website
• Protect the personal safety of users of the website or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our website does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our website may contain links to other websites that are not operated by us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Identity theft and fraud

What is identity theft and fraud?

Identity fraud is where someone impersonates You without Your knowledge or consent or uses Your personal information to obtain money, goods or services. More information on the types and incidences of identity fraud is available from the FCA website (opens in a new window), which contains tips on how to protect Yourself, what to do if it happens to You and contact details of organisations that can help.

How does identity theft and fraud occur?

It can occur when someone fraudulently represents a legitimate company – either online or by telephone – and tricks You into divulging personal information. A common method is phishing, the act of sending an email that fraudulently represents a legitimate company and lures You into revealing personal and financial information that could then be used for identity theft. In addition, these fraudulent emails may contain trojans or viruses.

A trojan is a computer programme that may seem innocent but has been designed to damage Your computer or send confidential information over the internet to another computer. A virus is a computer programme that runs on Your computer without Your knowledge. If You are in any doubt about whether an email is genuine do not open it or click on any links it contains.

How can I spot a scam or phishing email?

Initially, phishing emails look genuinely like those from financial services companies. They may have an official-looking logo and information taken from legitimate websites. However, there are things You should look out for:

• Virgil Alternative Investments, or its associates, will never contact You by telephone or email asking You to verify Your account details. You should not respond to any email asking You to verify Your account number or sign-on details, or seeking similar confirmations, which purports to be from Virgil Alternative Investments UK Ltd.
• Beware of links in emails. Always check financial websites carefully to make sure the web address is correct and is not spelt slightly differently.
• Genuine emails from Virgil Alternative Investments UK Ltd may contain links. However, we will not send any email with links to the online sign-in page.

What should I do if I have received a suspicious email?

• Forward the suspicious email to operation@vaiuk.finance
• Delete the email.
• Do not respond to or access any links contained within the email.

Contact Us

If you have any questions about these Terms and Conditions or our Privacy Policy, you can contact us by email at operation@vaiuk.finance.