www.vistra.com
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https://www.vistra.com/privacy-notice
Submission: On May 08 via manual from TH — Scanned from DE
Submission: On May 08 via manual from TH — Scanned from DE
Form analysis 7 forms found in the DOM
<form>
<fieldset>
<legend class="visuallyhidden">Consent Selection</legend>
<div id="CybotCookiebotDialogBodyFieldsetInnerContainer">
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<div class="CybotCookiebotDialogBodyLevelButtonWrapper"><label class="CybotCookiebotDialogBodyLevelButtonLabel" for="CybotCookiebotDialogBodyLevelButtonPreferences"><strong
class="CybotCookiebotDialogBodyLevelButtonDescription">Preferences</strong></label>
<div class="CybotCookiebotDialogBodyLevelButtonSliderWrapper"><input type="checkbox" id="CybotCookiebotDialogBodyLevelButtonPreferences" class="CybotCookiebotDialogBodyLevelButton CybotCookiebotDialogBodyLevelConsentCheckbox"
data-target="CybotCookiebotDialogBodyLevelButtonPreferencesInline" checked="checked" tabindex="0"> <span class="CybotCookiebotDialogBodyLevelButtonSlider"></span></div>
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<div class="CybotCookiebotDialogBodyLevelButtonWrapper"><label class="CybotCookiebotDialogBodyLevelButtonLabel" for="CybotCookiebotDialogBodyLevelButtonStatistics"><strong
class="CybotCookiebotDialogBodyLevelButtonDescription">Statistics</strong></label>
<div class="CybotCookiebotDialogBodyLevelButtonSliderWrapper"><input type="checkbox" id="CybotCookiebotDialogBodyLevelButtonStatistics" class="CybotCookiebotDialogBodyLevelButton CybotCookiebotDialogBodyLevelConsentCheckbox"
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<div class="CybotCookiebotDialogBodyLevelButtonWrapper"><label class="CybotCookiebotDialogBodyLevelButtonLabel" for="CybotCookiebotDialogBodyLevelButtonMarketing"><strong
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<form class="search-form" action="/search">
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placeholder="Enter search term" data-once="autocomplete search-api-autocomplete" autocomplete="off">
</div>
<input class="search-icon" type="submit">
</form>Text Content
* Consent
* Details
* [#IABV2SETTINGS#]
* About
THIS WEBSITE USES COOKIES
We use cookies to personalise content and ads, to provide social media features
and to analyse our traffic. We also share information about your use of our site
with our social media, advertising and analytics partners who may combine it
with other information that you’ve provided to them or that they’ve collected
from your use of their services.
Consent Selection
Necessary
Preferences
Statistics
Marketing
Show details
* Necessary 36
Necessary cookies help make a website usable by enabling basic functions like
page navigation and access to secure areas of the website. The website cannot
function properly without these cookies.
* Cookiebot
1
Learn more about this provider
1.gifUsed to count the number of sessions to the website, necessary for
optimizing CMP product delivery.
Expiry: SessionType: Pixel
* Google
7
Learn more about this provider
test_cookieUsed to check if the user's browser supports cookies.
Expiry: 1 dayType: HTTP
_GRECAPTCHAThis cookie is used to distinguish between humans and bots.
This is beneficial for the website, in order to make valid reports on the
use of their website.
Expiry: 180 daysType: HTTP
_grecaptchaThis cookie is used to distinguish between humans and bots.
This is beneficial for the website, in order to make valid reports on the
use of their website.
Expiry: PersistentType: HTML
rc::aThis cookie is used to distinguish between humans and bots. This is
beneficial for the website, in order to make valid reports on the use of
their website.
Expiry: PersistentType: HTML
rc::bThis cookie is used to distinguish between humans and bots.
Expiry: SessionType: HTML
rc::cThis cookie is used to distinguish between humans and bots.
Expiry: SessionType: HTML
rc::fThis cookie is used to distinguish between humans and bots.
Expiry: PersistentType: HTML
* LinkedIn
3
Learn more about this provider
bcookiePending
Expiry: 1 yearType: HTTP
li_gcPending
Expiry: 180 daysType: HTTP
bscookiePending
Expiry: 1 yearType: HTTP
* RudderStack
6
Learn more about this provider
#.#-#-#-#-#.ackUsed to contain user’s survey and quiz answers in Local
Storage.
Expiry: PersistentType: HTML
#.#-#-#-#-#.inProgressUsed to contain user’s survey and quiz answers in
Local Storage.
Expiry: PersistentType: HTML
#.#-#-#-#-#.queueUsed to contain user’s survey and quiz answers in Local
Storage.
Expiry: PersistentType: HTML
#.#-#-#-#-#.reclaimEndUsed to contain user’s survey and quiz answers in
Local Storage.
Expiry: PersistentType: HTML
#.#-#-#-#-#.reclaimStartUsed to contain user’s survey and quiz answers in
Local Storage.
Expiry: PersistentType: HTML
test_rudder_cookieThis cookie determines whether the browser accepts
cookies.
Expiry: 1 yearType: HTTP
* Typeform
2
Learn more about this provider
AWSALBTGRegisters which server-cluster is serving the visitor. This is
used in context with load balancing, in order to optimize user experience.
Expiry: 7 daysType: HTTP
AWSALBTGCORSRegisters which server-cluster is serving the visitor. This is
used in context with load balancing, in order to optimize user experience.
Expiry: 7 daysType: HTTP
* hsforms.com
vimeo.com
7
__cf_bm [x4]This cookie is used to distinguish between humans and bots.
This is beneficial for the website, in order to make valid reports on the
use of their website.
Expiry: 1 dayType: HTTP
_cfuvid [x3]This cookie is a part of the services provided by Cloudflare -
Including load-balancing, deliverance of website content and serving DNS
connection for website operators.
Expiry: SessionType: HTTP
* sgtm-cr.vistra.com
1
_set_cookieThis cookie determines whether the browser accepts cookies.
Expiry: SessionType: Pixel
* vistra.com
cn
com
com.cn
vistra.com.cn
vistrasedico.com
6
gtm_tld_testcookie [x6]Used to maintain visitors' preferences throughout
the visit and sub-pages.
Expiry: SessionType: HTTP
* vistrasedico.com
consent.cookiebot.com
3
CookieConsent [x3]Stores the user's cookie consent state for the current
domain
Expiry: 1 yearType: HTTP
* Preferences 9
Preference cookies enable a website to remember information that changes the
way the website behaves or looks, like your preferred language or the region
that you are in.
* LinkedIn
1
Learn more about this provider
lidcPending
Expiry: 1 dayType: HTTP
* YouTube
8
Learn more about this provider
VISITOR_INFO1_LIVETries to estimate the users' bandwidth on pages with
integrated YouTube videos.
Expiry: 180 daysType: HTTP
yt-remote-cast-availableStores the user's video player preferences using
embedded YouTube video
Expiry: SessionType: HTML
yt-remote-cast-installedStores the user's video player preferences using
embedded YouTube video
Expiry: SessionType: HTML
yt-remote-connected-devicesStores the user's video player preferences
using embedded YouTube video
Expiry: PersistentType: HTML
yt-remote-device-idStores the user's video player preferences using
embedded YouTube video
Expiry: PersistentType: HTML
yt-remote-fast-check-periodStores the user's video player preferences
using embedded YouTube video
Expiry: SessionType: HTML
yt-remote-session-appStores the user's video player preferences using
embedded YouTube video
Expiry: SessionType: HTML
yt-remote-session-nameStores the user's video player preferences using
embedded YouTube video
Expiry: SessionType: HTML
* Statistics 56
Statistic cookies help website owners to understand how visitors interact
with websites by collecting and reporting information anonymously.
* Google
4
Learn more about this provider
collectUsed to send data to Google Analytics about the visitor's device
and behavior. Tracks the visitor across devices and marketing channels.
Expiry: SessionType: Pixel
_gatUsed by Google Analytics to throttle request rate
Expiry: 1 dayType: HTTP
_gidRegisters a unique ID that is used to generate statistical data on how
the visitor uses the website.
Expiry: 1 dayType: HTTP
tdRegisters statistical data on users' behaviour on the website. Used for
internal analytics by the website operator.
Expiry: SessionType: Pixel
* Hotjar
9
Learn more about this provider
_hjTLDTest [x3]Registers statistical data on users' behaviour on the
website. Used for internal analytics by the website operator.
Expiry: SessionType: HTTP
hjActiveViewportIdsThis cookie contains an ID string on the current
session. This contains non-personal information on what subpages the
visitor enters – this information is used to optimize the visitor's
experience.
Expiry: PersistentType: HTML
hjViewportIdSaves the user's screen size in order to adjust the size of
images on the website.
Expiry: SessionType: HTML
_hjSession_# [x2]Collects statistics on the visitor's visits to the
website, such as the number of visits, average time spent on the website
and what pages have been read.
Expiry: 1 dayType: HTTP
_hjSessionUser_# [x2]Collects statistics on the visitor's visits to the
website, such as the number of visits, average time spent on the website
and what pages have been read.
Expiry: 1 yearType: HTTP
* Hubspot
12
Learn more about this provider
__hssc [x3]Identifies if the cookie data needs to be updated in the
visitor's browser.
Expiry: 1 dayType: HTTP
__hssrc [x3]Used to recognise the visitor's browser upon reentry on the
website.
Expiry: SessionType: HTTP
__hstc [x3]Sets a unique ID for the session. This allows the website to
obtain data on visitor behaviour for statistical purposes.
Expiry: 180 daysType: HTTP
hubspotutk [x3]Sets a unique ID for the session. This allows the website
to obtain data on visitor behaviour for statistical purposes.
Expiry: 180 daysType: HTTP
* LinkedIn
1
Learn more about this provider
AnalyticsSyncHistoryPending
Expiry: 30 daysType: HTTP
* RudderStack
6
Learn more about this provider
rl_anonymous_idRegisters statistical data on users' behaviour on the
website. Used for internal analytics by the website operator.
Expiry: PersistentType: HTML
rl_group_idRegisters statistical data on users' behaviour on the website.
Used for internal analytics by the website operator.
Expiry: PersistentType: HTML
rl_group_traitRegisters statistical data on users' behaviour on the
website. Used for internal analytics by the website operator.
Expiry: PersistentType: HTML
rl_sessionCollects data on the user's visits to the website, such as the
number of visits, average time spent on the website and what pages have
been loaded with the purpose of generating reports for optimising the
website content.
Expiry: PersistentType: HTML
rl_traitRegisters statistical data on users' behaviour on the website.
Used for internal analytics by the website operator.
Expiry: PersistentType: HTML
rl_user_idRegisters statistical data on users' behaviour on the website.
Used for internal analytics by the website operator.
Expiry: PersistentType: HTML
* Twitter Inc.
1
Learn more about this provider
personalization_idThis cookie is set by Twitter - The cookie allows the
visitor to share content from the website onto their Twitter profile.
Expiry: 400 daysType: HTTP
* Typeform
2
Learn more about this provider
dd_cookie_test_#Registers data on visitors' website-behaviour. This is
used for internal analysis and website optimization.
Expiry: 1 dayType: HTTP
tracking_session_idDetermines when the visitor last visited the different
subpages on the website, as well as sets a timestamp for when the session
started.
Expiry: 1 dayType: HTTP
* Vimeo
1
Learn more about this provider
vuidCollects data on the user's visits to the website, such as which pages
have been read.
Expiry: 2 yearsType: HTTP
* sgtm-cr.vistra.com
www.google-analytics.com
4
_ga [x4]Registers a unique ID that is used to generate statistical data on
how the visitor uses the website.
Expiry: 2 yearsType: HTTP
* sgtm-cr.vistra.com
www.googletagmanager.com
7
_ga_# [x3]Used by Google Analytics to collect data on the number of times
a user has visited the website as well as dates for the first and most
recent visit.
Expiry: 2 yearsType: HTTP
_gcl_au [x4]Used by Google AdSense for experimenting with advertisement
efficiency across websites using their services.
Expiry: 3 monthsType: HTTP
* vistra.com
6
FPGSIDRegisters statistical data on users' behaviour on the website. Used
for internal analytics by the website operator.
Expiry: 1 dayType: HTTP
FPIDRegisters statistical data on users' behaviour on the website. Used
for internal analytics by the website operator.
Expiry: 400 daysType: HTTP
FPLCRegisters a unique ID that is used to generate statistical data on how
the visitor uses the website.
Expiry: 1 dayType: HTTP
gtm_productCategoryPending
Expiry: 180 daysType: HTTP
gtm_productNamePending
Expiry: 180 daysType: HTTP
gtm_productSkuPending
Expiry: 180 daysType: HTTP
* vistra.com
vistra.com.cn
2
gtm_hotjarClientID [x2]Pending
Expiry: 534 daysType: HTTP
* www.vistra.com
1
PARMONIC_SESSION_IDThis cookie contains an ID string on the current
session used by Parmonic video tool.
Expiry: PersistentType: HTML
* Marketing 37
Marketing cookies are used to track visitors across websites. The intention
is to display ads that are relevant and engaging for the individual user and
thereby more valuable for publishers and third party advertisers.
* Casale Media
4
Learn more about this provider
CMIDCollects visitor data related to the user's visits to the website,
such as the number of visits, average time spent on the website and what
pages have been loaded, with the purpose of displaying targeted ads.
Expiry: 1 yearType: HTTP
CMPROCollects data on visitor behaviour from multiple websites, in order
to present more relevant advertisement - This also allows the website to
limit the number of times that they are shown the same advertisement.
Expiry: 3 monthsType: HTTP
CMPSCollects visitor data related to the user's visits to the website,
such as the number of visits, average time spent on the website and what
pages have been loaded, with the purpose of displaying targeted ads.
Expiry: 3 monthsType: HTTP
rumCollects data related to the user's visits to the website, such as the
number of visits, average time spent on the website and what pages have
been loaded, with the purpose of displaying targeted ads.
Expiry: SessionType: Pixel
* DemandBase
2
Learn more about this provider
tuuidCollects visitor data related to the user's visits to the website,
such as the number of visits, average time spent on the website and what
pages have been loaded, with the purpose of displaying targeted ads.
Expiry: 400 daysType: HTTP
tuuid_luContains a unique visitor ID, which allows Bidswitch.com to track
the visitor across multiple websites. This allows Bidswitch to optimize
advertisement relevance and ensure that the visitor does not see the same
ads multiple times.
Expiry: 400 daysType: HTTP
* Google
7
Learn more about this provider
IDEPending
Expiry: 1 yearType: HTTP
pagead/landingCollects data on visitor behaviour from multiple websites,
in order to present more relevant advertisement - This also allows the
website to limit the number of times that they are shown the same
advertisement.
Expiry: SessionType: Pixel
ads/ga-audiencesUsed by Google AdWords to re-engage visitors that are
likely to convert to customers based on the visitor's online behaviour
across websites.
Expiry: SessionType: Pixel
pagead/1p-conversion/#/Pending
Expiry: SessionType: Pixel
pagead/1p-user-list/#Pending
Expiry: SessionType: Pixel
#,#Collects data on user behaviour and interaction in order to optimize
the website and make advertisement on the website more relevant.
Expiry: PersistentType: HTML
#,#_expiresAtCollects data on user behaviour and interaction in order to
optimize the website and make advertisement on the website more relevant.
Expiry: PersistentType: HTML
* Hubspot
1
Learn more about this provider
__ptq.gifSends data to the marketing platform Hubspot about the visitor's
device and behaviour. Tracks the visitor across devices and marketing
channels.
Expiry: SessionType: Pixel
* LinkedIn
4
Learn more about this provider
collect/Collects data on user behaviour and interaction in order to
optimize the website and make advertisement on the website more relevant.
Expiry: SessionType: Pixel
li_sugrPending
Expiry: 3 monthsType: HTTP
UserMatchHistoryPending
Expiry: 30 daysType: HTTP
li_adsIdCollects data on user behaviour and interaction in order to
optimize the website and make advertisement on the website more relevant.
Expiry: PersistentType: HTML
* RudderStack
3
Learn more about this provider
rl_page_init_referrerRegisters how the user has reached the website to
enable pay-out of referral commission fees to partners.
Expiry: PersistentType: HTML
rl_page_init_referring_domainRegisters how the user has reached the
website to enable pay-out of referral commission fees to partners.
Expiry: PersistentType: HTML
__tld__Used to track visitors on multiple websites, in order to present
relevant advertisement based on the visitor's preferences.
Expiry: SessionType: HTTP
* Telaria
2
Learn more about this provider
tv_UIDMPending
Expiry: 400 daysType: HTTP
tvidPresents the user with relevant content and advertisement. The service
is provided by third-party advertisement hubs, which facilitate real-time
bidding for advertisers.
Expiry: 1 yearType: HTTP
* Twitter Inc.
3
Learn more about this provider
i/adsct [x2]The cookie is used by Twitter.com in order to determine the
number of visitors accessing the website through Twitter advertisement
content.
Expiry: SessionType: Pixel
muc_adsCollects data on user behaviour and interaction in order to
optimize the website and make advertisement on the website more relevant.
Expiry: 400 daysType: HTTP
* Typeform
3
Learn more about this provider
#-visitorIdPending
Expiry: PersistentType: HTML
attribution_user_idUsed in context with the website’s pop-up
questionnaires and messengering. The data is used for statistical or
marketing purposes.
Expiry: 1 yearType: HTTP
tf_respondent_ccUsed to implement forms on the website.
Expiry: 6 monthsType: HTTP
* YouTube
8
Learn more about this provider
LAST_RESULT_ENTRY_KEYUsed to track user’s interaction with embedded
content.
Expiry: SessionType: HTTP
LogsDatabaseV2:V#||LogsRequestsStorePending
Expiry: PersistentType: IDB
remote_sidNecessary for the implementation and functionality of YouTube
video-content on the website.
Expiry: SessionType: HTTP
ServiceWorkerLogsDatabase#SWHealthLogNecessary for the implementation and
functionality of YouTube video-content on the website.
Expiry: PersistentType: IDB
TESTCOOKIESENABLEDUsed to track user’s interaction with embedded content.
Expiry: 1 dayType: HTTP
VISITOR_PRIVACY_METADATAStores the user's cookie consent state for the
current domain
Expiry: 180 daysType: HTTP
YSCRegisters a unique ID to keep statistics of what videos from YouTube
the user has seen.
Expiry: SessionType: HTTP
YtIdbMeta#databasesUsed to track user’s interaction with embedded content.
Expiry: PersistentType: IDB
* Unclassified 0
Unclassified cookies are cookies that we are in the process of classifying,
together with the providers of individual cookies.
We do not use cookies of this type.
Cross-domain consent3 Your consent applies to the following domains:
List of domains your consent applies to: vistra.com.cn vistrasedico.com
vistra.com
Cookie declaration last updated on 24.04.24 by Cookiebot
[#IABV2_TITLE#]
[#IABV2_BODY_INTRO#]
[#IABV2_BODY_LEGITIMATE_INTEREST_INTRO#]
[#IABV2_BODY_PREFERENCE_INTRO#]
[#IABV2_LABEL_PURPOSES#]
[#IABV2_BODY_PURPOSES_INTRO#]
[#IABV2_BODY_PURPOSES#]
[#IABV2_LABEL_FEATURES#]
[#IABV2_BODY_FEATURES_INTRO#]
[#IABV2_BODY_FEATURES#]
[#IABV2_LABEL_PARTNERS#]
[#IABV2_BODY_PARTNERS_INTRO#]
[#IABV2_BODY_PARTNERS#]
Cookies are small text files that can be used by websites to make a user's
experience more efficient. The law states that we can store cookies on your
device if they are strictly necessary for the operation of this site. For all
other types of cookies we need your permission.
This site uses different types of cookies. Some cookies are placed by third
party services that appear on our pages. You can at any time change or withdraw
your consent from the Cookie Declaration on our website.
Learn more about who we are, how you can contact us and how we process personal
data in our Cookie Policy.
Do not sell or share my personal information
Use necessary cookies only Allow selection Cookie options
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PRIVACY NOTICE
Effective Date: from 21 April 2021
The Privacy Notices included below explain how particular companies in the
Vistra Group collect, use and disclose your personal data, and your rights in
relation to the personal data they hold.
Please select which Vistra office and location is applicable to you:
Australia | Belgium | Brazil | British Virgin Islands – Vistra Licence Holdings
(BVI) Limited | British Virgin Islands – Vistra Trust (BVI) Limited | Bulgaria |
Canada | Cayman Islands | People's Republic of China | Cyprus | Czech Republic |
Eumetra AG, Switzerland | Vistra Geneva SA, Switzerland | Germany | Guernsey |
Hong Kong SAR | India | Indonesia | Ireland | Japan | Jersey | Vistra Luxembourg
S.à r.l. | Vistra Luxembourg Fund Management S.A | Macau SAR | Malaysia | Malta
| Marine and Aviation | Mauritius | Monaco | Netherlands | Poland | Poland Fund
Services | Romania | Seychelles | Spain | Slovakia | Singapore | Taiwan | United
Arab Emirates | USA | London (UK) | Vistra Depository Services (UK) | Vistra
Business Information (UK) | Vistra Corporate Law (UK) | Vistra Legalisation
Services Limited (UK) | Vistra-Trustees GmbH, Switzerland | Bristol and Scotland
(UK) | Vistra International Expansion (UK) | Vistra Zug AG, Switzerland | Vistra
Zurich AG, Switzerland
Please note that Vistra Group Holdings (BVI) Limited or its relevant Vistra
group entity (“us”, “we” and “our”) is the controller of your personal data and
is subject to applicable data protection laws and regulations, which may
include, but not be limited to, the EU General Data Protection Regulation
2016/679 and the Personal Data Privacy Ordinance (Chapter 486 of the laws of
Hong Kong) (collectively, the “Applicable Data Protection Laws”).
In case of any question or comment in respect of this Privacy Notice, please
contact:
By post:
General Counsel
Vistra Group, 19th Floor, Lee Gardens One, Causeway Bay, Hong Kong
By email:
privacy@vistra.com
By telephone:
+852 2521 3661
This Privacy Notice supersedes any previous Privacy Notice or equivalent which
you may have been provided with or seen prior to the Effective Date stated
above.
Your rights
Under the Applicable Data Protection Laws, you may have (any of) the following
rights:
• To obtain access to, and copies of, the personal data that we hold about
you;
• To require that we cease processing your personal data if the processing is
causing you damage or distress;
• To require us not to send you marketing communications;
• To require us to erase your personal data;
• To require us to restrict our data processing activities;
• To receive from us the personal data we hold about you which you have
provided to us, in a reasonable format specified by you, including for the
purpose of you transmitting that personal data to another data controller; and
• To require us to correct the personal data we hold about you if it is
incorrect.
Please note that the above rights are not absolute, and we may be entitled to
refuse requests where exceptions apply.
To find out more about your rights, please refer to the relevant data protection
governmental body or regulatory authority (as the case may be) in the place
where you are located.
If you have any questions about how we use your personal data, or you wish to
exercise any of the rights set out above, please contact us via any of the
contact details listed above.
If you are not satisfied with how we are processing your personal data, you can
make a complaint with us directly via the contact details above, and/or to the
relevant data protection governmental body or regulatory authority (as the case
may be) in the place where you are located.
How we collect your data
We may collect your personal data in a number of ways, for example:
• From the information you provide to us when you meet us;
• From information about you provided to us by your company or an
intermediary;
• When you communicate with us by telephone, fax, email or other forms of
electronic communication. In this respect, we may monitor, record and store any
such communication;
• When you complete (or we complete on your behalf) client on-boarding or
application or other forms;
• From other companies in the Vistra Group;
• From your agents, advisers, intermediaries, and custodians of your assets;
• From publicly available sources or from third parties, most commonly where
we need to conduct background checks or pre-employment screening about you;
• During the recruitment process, you (as job applicant) may be required to
provide sufficient personal data so that we may, as appropriate and/or
applicable, assess your suitability for the position being applied for; and
• From the information you provide to us when you contact us or when you make
a job application with us.
The categories of personal data we collect
We may collect the following categories of personal data about you:
• Your name and contact information such as your home or business address,
email address and telephone number;
• Biographical information which may confirm your identity including your
date of birth, tax identification number and your passport number or national
identity card details, country of domicile and/or your nationality;
• Information relating to your financial situation such as income,
expenditure, assets and liabilities, sources of wealth, as well as your bank
account details;
• Information about your knowledge and experience in the investment field;
• An understanding of your goals and objectives in procuring our services;
• Information about your employment, education, family or personal
circumstances, and interests, where relevant;
• Information to assess whether you may represent a politically exposed
person or money laundering risk; and
• Such other categories of personal data as may be the case.
The basis for processing your personal data (other than with your consent), how
we use that personal data and whom we share it with
(i) Performance of a contract with you
We may process your personal data because it is necessary for the performance of
a contract to which you are a party or in order to take steps at your request
prior to entering into a contract.
In this respect, we may use your personal data for the following:
• To prepare a proposal for you regarding the services we offer;
• To provide you with the services as set out in our services agreement or
terms of engagement with you or as otherwise agreed with you from time to time;
• To deal with any complaints or feedback you may have;
• For any other purpose for which you provide us with your personal data; and
• For background checks and pre-employment screenings, including conducting
such checks and screenings on job applicants and employees.
(ii) Legitimate interests
We may also process your personal data because it is necessary for our
legitimate interests, or sometimes where it is necessary for the legitimate
interests of another person.
In this respect, we may use your personal data for the following:
• For marketing to you. In this respect, see the separate section on
“Marketing” below;
• Training our staff or monitoring their performance;
• For the administration and management of our business, including recovering
money you owe to us, and archiving or statistical analysis;
• To protect our rights or those of you and/or our clients and/or to prevent
fraud;
• To develop and improve our services or to strengthen our relationship with
you;
• Seeking advice on our rights and obligations, such as where we require our
own legal advice;
• For security purposes, including by operating security cameras in various
locations at Vistra’s premises, and conducting background checks and
pre-employment screenings; and
• Monitoring and recording telephone calls and emails and internet use in
accordance with our IT policies.
(iii) Legal obligations
We may also process your personal data for our compliance with a legal
obligation which we are under.
In this respect, we may use your personal data for the following:
• To meet our legal, compliance and regulatory obligations, such as
compliance with anti-money laundering laws;
• As required by tax authorities or any competent court or legal authority;
• Monitoring and recording telephone calls and emails, and conducting
background checks and pre-employment screenings for compliance with our
regulatory obligations; and
• For the prevention and detection of crime, and in order to assist with
investigations (including criminal investigations) carried out by the police and
other competent authorities.
Data Sharing
We may share your personal data with or transfer it to the following parties:
• Your agents, advisers, intermediaries, and custodians of your assets who
you tell us about;
• Third parties whom we engage to assist in delivering the services to you,
including vendors and other companies in the Vistra Group;
• Our professional advisers where it is necessary for us to obtain their
advice or assistance, including lawyers, accountants, IT or public relations
advisers;
• Other third parties such as intermediaries who we introduce to you. We will
wherever possible tell you who they are before we introduce you;
• Competent authorities in order to comply with our legal and/or regulatory
obligations; and
• Our hosting partner and (cloud or server based) data storage providers.
Marketing
We may send you marketing communications about similar or related services we
provide, as well as other information in the form of alerts, newsletters and
invitations to events or functions which we believe might be of interest to you.
We may communicate this to you in a number of ways including by post, telephone,
email, SMS or other digital channels.
If you object to receiving marketing from us at any time, please click the
“unsubscribe” button in the relevant email communication, or contact us via any
of the contact details stated above.
Cookies
Our website uses cookies to improve your experience on our website. For full
details on how cookies are used, please see our Cookie Policy.
Transfer and processing of your personal data cross-border
We may transfer, store, or process your personal information in locations
outside the jurisdiction in which you are based (“Jurisdiction”). Where the
countries to which your personal information is transferred do not offer an
equivalent level of protection for personal information to the laws of the
Jurisdiction, we will ensure that appropriate and reasonable safeguards and
security measures are put in place.
Where we transfer your personal information from the Jurisdiction, we will only
do so in compliance with any applicable data protection laws and regulations.
To find out more about transfers by us of your personal data outside the
Jurisdiction or any countries concerned, please contact us via any of the
contact details stated above.
Retention of your data
We will retain your personal data for as long as is considered necessary for the
purpose for which it was collected (including as required by applicable law or
regulation). In particular:
• where we have collected your personal data as required by anti-money
laundering and counter-terrorist financing legislation, including for
identification, screening and reporting, we will normally retain that personal
data for five (5) years after the termination of our relationship, unless we are
required to retain this information by another law or for the purposes of court
proceedings;
• we will in most cases retain your personal data for a period of seven (7)
years after the termination of our contractual or other relationship with you in
case any claims arise out of the provision of our services to you; or
• in the case of unsuccessful applicants who applied via Vistra’s V-Connect
applicant portal, unless otherwise notified to you, we will retain and use the
information you provided to us for a period of 365 days from the date you last
logged into your V-Connect account.
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