Verge Management Group, LLCor “VMG”, (“we”, “us” and “our”) is committed to protecting and respecting the personal data that we hold. This GDPR privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for the purposes described in this privacy statement or as made clear before collecting personal data. Personal data is any information relating to an identified or identifiable living person. When collecting and using personal data, our policy is to be transparent about why and how we process personal data. We process personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose are set out in the relevant sections below. The personal data that is provided to us is provided either directly from the individual concerned, from a third party acting on behalf of an individual, or from publicly available sources.
We take the security of all the data we hold seriously. Staff involved in data processing are trained on data protection, confidentiality and security.
We have a framework of policies and procedures which ensure we regularly review the appropriateness of the measures we have in place to keep the data we hold secure.
All information you provide to us is stored securely. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site or systems, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the internet; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
2. Data that we hold
2.1 Professional Services
We provide services primarily to businesses, other organizations and, in limited circumstances, individuals. The exact data held will depend on the services to be provided.
Where we engage with clients for professional services, we may collect and process personal data to satisfy a contractual obligation or regulatory requirements. We request that clients only provide the personal data that is required for us to fulfill our contractual obligation or regulatory requirements.
2.1.1 Why do we process data?
Where data is collected for professional services, it is used for several purposes, as follows;
• Providing services to clients. Data is processed in accordance with our terms and conditions of engagement between our clients and us and may sometimes be further clarified in written documentation supplied before any data processing may occur. We provide a range of professional services to our clients, which includes:
• Client management. When communicating with and assessing the needs of clients, personal data may be processed to ensure that their needs are appropriately satisfied. This may include assessing whether the range of services provided to our clients is appropriate.
• Administration. To manage and administer our business and services, we may collect and process personal data. This may include (but is not limited to) maintaining internal business records, managing client relationships, hosting events, administering client facing applications, and maintaining internal operating processes.
• Regulatory. To undertake professional services, we may from time to time be required to collect and process personal data to fulfill regulatory, legal or ethical requirements. This may include (but is not limited to) the verification of identity of individuals.
2.1.2 What data is processed?
The data that is processed is dependent on the service that is being provided and on the recipient of this service.
• Services to businesses and other organizations. We process the personal data of individuals associated with our clients. Personal data may include any relevant financial or non-financial information necessary for us to provide our services.
• Services to individuals. Personal data may include contact details and tax identifiers, information about business activities, investments, and other commercial interests, and any other specifically relevant data.
2.1.3 How long do we hold data for?
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation). We may keep data for longer to establish, exercise, or defend our legal rights and the legal rights of our clients. In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a legitimate need (i.e. regulatory) to continue to retain such information.
2.2 People who use our website and mobile apps
When people visit our website, personal data is collected both through automated tracking and interacting with various forms on the website or apps (collectively referred to as the websites).
Personal data may be collected when individuals fill in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information provided when individuals subscribe to our services, make an inquiry, comment on publications, apply to work for VMG and report a problem with our website.
When individuals visit our websites, certain personal data may be automatically collected. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies).
Often, individuals who visit our website additionally fall into another category as listed by this privacy statement. For instance, users of our websites may be current clients, business contacts or become clients in the future. Where this is the case, data held and processed for individuals who use our website may also become data that is held and processed for another purpose.
2.2.1 Why do we process data?
There are several reasons why we will process the personal data that an individual may provide to us when visiting our websites. As examples, these include;
• Administration. In to administer our site and to improve internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. For example, we use this data to ensure that the website is presented well for individuals and is optimized appropriately.
• Functionality. To allow individuals to use some functionality of our website, certain personal data must be entered for features to work as intended.
• Security. To keep our site safe and secure, we may sometimes collect personal data, for instance, login information and other data that can be used to verify identity.
• Promote and develop our offerings. Some personal data may be used to measure or understand the effectiveness of advertising we serve to individuals, and to ensure that only relevant advertising appears.
2.2.2 What data do we hold?
The data that we hold depends on what data was entered and for what purpose.
Where data was entered to engage with the functionality of our website, that personal data may include their name, address, e-mail address and phone number.
Where data is collected automatically, the data that we may collect includes technical information, including the Internet protocol (IP) address used to connect an individual’s computer to the Internet, login information, browser type, and version, time zone setting, browser plug-in types, and versions, operating system and platform;
Other data about an individual’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number or email address used to contact us.
2.2.3 How long do we hold data for?
We retain the personal data processed by us in a live environment for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation, typically 6 years).
In addition, personal data may be securely archived with restricted access and other appropriate safeguards where there is a need to continue to retain it.
2.3 Corporate Administration
We collect personal data for our people as part of the administration, management and promotion of our business activities.
Our staff handbook, personnel policies and procedures explain further how personal data is held for our staff.
Where an individual is applying to work for VMG, personal data is collected through the application process which includes but is not limited to a website application process. Details can be found in the section describing people who use our website. Data collected via the website will be used for the purposes detailed below.
• Employment. We process an applicant’s personal data to assess their potential employment at VMG.
• Administration and management. We may also use this personal data to make informed management decisions and for administration purposes.
Personal data collected for applicants is held for as long as necessary to fulfill the purpose for which it was collected, or for a maximum of two years where those purposes no longer become necessary. 2.3.2 Suppliers and Other Service Providers
We collect and process personal data about our suppliers, subcontractors, other service providers and individuals associated with them. The data is held to manage our relationship, to contract and receive services from them, and to provide professional services to our clients.
2.3.3 Why do we process data?
• Receiving goods and services. We process personal data in relation to our suppliers and their staff as necessary to receive the services.
• Providing services to our clients. Where a supplier or other service provider is helping us to deliver professional services to our clients, we process personal data about the individuals involved in providing the services to administer and manage our relationship with the supplier or other service provider and the relevant individuals and to provide such services to our clients.
• Administering, managing and developing our businesses and services. We process personal data to run our business, including:
o managing our relationship with suppliers;
o developing our businesses and services (such as identifying client needs and improvements in service delivery);
o maintaining and using IT systems;
o hosting or facilitating the hosting of events; and
o administering and managing our website and systems and applications.
• Security, quality and risk management activities. We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to our suppliers. We collect and hold personal data as part of our supplier contracting procedures. We monitor the services provided for quality purposes, which may involve processing personal data.
• Promoting our services. We may use business contact details to provide information that we think will be of interest about us and our services. For example, industry updates and insights, other services that may be relevant and invites to events.
• Complying with any requirement of law, regulation or a professional body of which we are a member. We are subject to legal, regulatory and professional obligations. We need to keep certain records to show we comply with those obligations and those records may contain personal data.
2.3.4 What data do we hold?
Personal data that may be held includes, but is not limited to, name, email address, physical address, job title.
2.3.5 How long do we hold data for?
We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). Data may be held for longer periods where required by law or regulation and to establish, exercise or defend our legal rights.
3. Sharing personal data
We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards. Personal data held by us may be transferred to:
Third party organizations that provide operational support, employee benefits and services, applications/functionality, data processing or IT services to us.
We use third parties to support us in providing our services and to help provide, run and manage our business and our internal IT systems. For example, providers of information technology, cloud-based software as a service provider, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are in secure data centers around the world, and personal data may be stored in any one of them.
Third party organizations that otherwise assist us in providing goods, services or information on VMG businesses, Auditors and other professional advisers,Law enforcement or regulatory agencies or those required by law or regulations. Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfill requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
4. Locations of processing
Data may be transferred to, and stored at, a destination outside the European Economic Area (EEA), under data transfer agreements, corporate binding rules or otherwise provided by GDPR. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will take all reasonable steps to ensure that data is treated securely, in accordance with this privacy statement.
5. Individual’s Rights
Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights as follows:
• Individuals may request access to their personal data held by us as a data controller.
• Individuals may request us to rectify personal data submitted to us or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which they registered.
• Individuals may request that we erase their personal data.
• Where we process personal data based on consent, individuals may withdraw their consent at any time by contacting us or clicking on the unsubscribe link in an email received from us.
• Individuals may have other rights to restrict or object to our processing of personal data and the right to data portability.
• Individuals may request information about, or human intervention into, any automated data processing that we may undertake.
If you wish to exercise any of these rights, please send an email to [email protected]
6. Contact Information
If you have any concerns about our use of personal data, please send an email with the details of your concerns to firstname.lastname@example.org
7. Changes to our privacy statement Updates to this privacy statement will appear on our website. This privacy statement was last updated on July 1, 2021 date