Verge.Capital

Privacy Policy

1. Introduction

This Privacy Policy applies to the website, mobile application or other digital service (each a “Digital Service”) linking to this Privacy Policy and owned or operated by Verge Capital LTD or its affiliates or subsidiaries  (collectively or individually, as applicable, referred to as “we”, “us”, “our” or “VERGE”).

This Privacy Policy describes how VERGE collects and processes personal information about you, how we use and protect this information and your rights.

This Privacy Policy describes the privacy practices of VERGE only and does not cover the practices of other companies. The Digital Services, including the articles, reports, solutions and other products and services made available through the Digital Services (collectively, the “Materials”), are made available for informational and research purposes and are intended for users acting in a professional capacity.

Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Digital Service. Please review the “LAST UPDATED” legend at the top of this page to determine when this Privacy Policy was most recently revised.

Please note that access to certain Digital Services may require a subscription, such as to the Verge Capital LTD credit score or other database, and may be subject to additional terms. Note that different types of data may be obtained depending on the Digital Service. Where the practices for a certain Digital Service differ from the general practices, this is called out specifically.

2. What information we obtain

When you use a Digital Service, we obtain various types of information related to you and your use of the Digital Service or Materials. This data includes information that directly identifies you such as your name, job title, or contact information as well as information such as online identifiers or cookie-level data that may indirectly identify you. The information we obtain generally consists of information (a) you provide us about yourself or that we directly collect from you, (b) you provide us about others, (c) automatically collected about your interactions with the Digital Services or Materials, and (d) we get from other sources as described further below.

A. Information we obtain directly from you

VERGE asks you to provide information about yourself when you use the Digital Services, including when you create an account, complete a form or subscribe to a mailing list. You may not be able to use certain features if you choose not to submit the requested information.

The information you provide us or that we directly obtain from you includes details such as:

  • Contact information (e.g., your name, email address, job title, company name).
  • Demographic and interests information (e.g., region, industry sector, preferred language, topics of interest).
  • Payment information for purchases made through the Digital Services (e.g., payment card number, expiration date and billing information). This information is used for the limited purposes of processing your transaction, providing you with the Materials and to protect our rights or the rights of others.
  • Information you choose to share with us (e.g., when you submit an inquiry through an online form on a Digital Service).
  • Transactional and activity information (e.g., requests, searches or orders).
  • If you apply for a course administered by VERGE, we may request further details from you. This information is used for purposes of assessing your qualification for the course and may include:
    • Educational background and work experience.
    • Date of birth.
    • Information provided by you in your personal statement and other information you choose to share with us in support of your application for the course.

You do not have to provide us with any personal data to visit our wesite. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of our website and/or a Digital Service.

Moreover, we may use third-party payment services (each, a “Payment Service”) to collect payments made through the site. If you wish to make a payment through the site, you may be directed to a webpage that is hosted by the Payment Service provider (or the Payment Service’s service providers) and not by VERGE. Any personal data that you provide through a Payment Service page will be collected by Payment Service’s service provider and not by VERGE, and will be subject to Payment Service’s privacy policy, rather than this Privacy Policy. VERGE has no control over, and is not responsible for, Payment Service’s use of information collected through the Payment Service page.

B. Information you provide about others

You may provide information about other people, such as the name and email of a contact with whom you want to share our reports, or the name, job title and contact information of a member of staff for whom you are purchasing a training. Do not give us information about others unless you are authorized or have their permission to do so. We will use their information for the purposes described in this Privacy Policy.

C. Information automatically collected

The Digital Services automatically log certain information about visits to the Digital Services, such as the number and frequency of visitors, technical information about browsers and devices used to access the Digital Services, and information about crashes or other technical issues. In addition, in accordance with your expressed preferences, we and third parties automatically collect certain information through cookies and similar tools (referred collectively as “Cookies and Similar Technologies”) about your activities over time across the Digital Services as well as across third-party sites, apps or other media. Some Cookies and Similar Technologies assign or collect unique cookie IDs or other identifiers associated with your browser or device. Cookies and Similar Technologies may collect information while you are using the Digital Services or while they are running in the background of your device. More information about the Cookies and Similar Technologies used on the Digital Services, including how to manage your preferences, is set out in the Cookie Policy.

The information automatically collected includes the following:

  • Information about your computer, device, browser and operating system (e.g., type, model, or version).
  • Internet protocol (IP) address, which is used to derive your general geographic area (e.g., city and country).
  • Device identifiers.
  • Information about your interactions with the Digital Services, including browsing activities and clickstream data that reflect the Materials you have accessed, clicked on, or viewed.
  • Information about how you accessed the Digital Services, including details about websites or apps visited immediately before or after accessing a Digital Service.
  • Demographic and interests information (e.g., region, industry sector, preferred language, topics of interest).
  • Information about your interactions with email messages and other communications, such as whether you opened or forwarded the email or clicked on links contained in the email.

For more information about the use of automated means in the context of interest-based advertising and how you can limit tracking, see our Cookie Policy further below.

D. Information we obtain from other sources

VERGE receives information about you from other sources which may be combined with information obtained about you as a result of your interactions with the Digital Services or Materials. For example, we obtain data from:

  • Third-party data suppliers such as data aggregators, data resellers, public databases and business partners. These suppliers provide us with demographic information, information about your organization, and other information that helps us learn about you and other users of the Digital Services.
  • Your organization or other individuals at your organization if you are authorized to access a Digital Services and/or Materials via a corporate account.
  • Operators of third-party sites, platforms or other devices and technologies when you interact with the Materials on those channels and platforms.
  • Social Media Platforms and similar services (“Social Media Platforms”). We obtain information from Social Media Platforms such as LinkedIn, which may include your username, user ID, demographic information and other information, subject to the settings and privacy practices of the relevant Social Media Platform.

The categories of information that we collect about you from other sources are your personal details (for example your name and date of birth) and your contact details (such as your phone number, email address, postal address or mobile number).

3. How we use the information we obtain

VERGE uses the information we obtain:

 To provide you with the Digital Services. This service includes:

  • Enabling you, as a new/returning customer, to access our website and use our Digital Services.
  • Processing your requests regarding the Digital Services and the Materials.
  • Providing customer assistance or technical support.
  • Customizing the Digital Services and Materials, providing recommendations and enhancing the quality and your overall experience with the Digital Services, including by retaining your user preferences or optimizing the presentation of the Digital Services and Materials based on your industry or interests and for the browser or device you use to access the Digital Services.
  • Maintaining, operating, improving and developing the Digital Services, Materials and other VERGE products and services.
  • Learning about users of the Digital Services and analyzing how you and others interact with and respond to the Digital Services and Materials, including by measuring and optimizing usage, reliability and performance, conducting market research, performing analytics, and supporting our operations (e.g., for accounting, auditing, financial, legal or other purposes).
  • Processing payments and collecting potential arrears. We will use your information to process the payments you commit to when signing up to our Digital Services and for the collection of any future payments or overdue amounts for thoseYour payment card provider may let us know if the card details relating to your VERGE payment change. If this happens, we reserve the right to update certain card details to makesure your access to our services isn’t interrupted.So for example, if you get a new payment card with a later expiry date to the one youcurrently pay with (but all the other details stay the same), we may update your paymentcard expiry date accordingly.
  • Providing and improving customer support. We will use your information to be able to provide and improve the customer support weprovide to you (e.g. when you have questions or when you forget your log-in information).

Sending you product eligibility alerts. As part of our Digital Services VERGE may retrieve and use your credit bureau data to check your eligibility for third party products or services and notify you of credit opportunities, products and services that you may be eligible for. When you log in to the website, we may show you updated eligibility ratings for products and services that may be available to you. As part of this service we may also notify you by e-mail, SMS or post of new or updated eligibility ratings for products and services; for example if new products and services are added, or your eligibility has changed. You can choose not to receive email, SMS and postal communications about product eligibility whenever you want from your VERGE account page.

A. To communicate with you. This activity includes:

  • Sending you Materials you have requested or which we believe are of interest to you.
  • Sending you informational messages about the Digital Services (e.g., to confirm your access to the relevant Materials or notify you of changes to a Digital Service).
  • Delivering marketing or promotional communications.
  • Responding to your questions or addressing your requests.
  • Providing you with surveys regarding the Digital Services.
  • Letting you know, through email, SMS, push notification, about significant changes to our products, terms or privacy policy.
  • Providing information related to your use of our Digital Services. When you search for products, we may contact you by email or SMS to confirm activityrelating to use of specific Digital Services, such as details of the searches you have made,results that you have seen when searching, or information about introductions you’verequested to brokers and lenders.

B. To protect our rights or the rights of others. This protection includes:

  • Confirming, for security purposes, your identity and authenticating the information you provide. Establishing your identity is important as the Digital Service may provide you with your personalcredit information (such as your credit score or credit report) and we must be sure you arewho you say you are. Identity checking may also involve checking the registrationinformation you give us against information we already hold about you as a credit referenceagency and potentially publicly available information about you such as from social media.If we are unable to confirm your identity from the registration information you provide, wewill let you know by using the contact details you have provided and you may then have theoption to make a written application and provide further proof of your identity.
  • Detecting, preventing and responding to fraud or potentially illegal activities, misuse of the Digital Services, intellectual property infringement or other violations of law, this Privacy Policy, our Terms of Use or other VERGE
  • Performing audits, assessments and testing or troubleshooting activities.
  • Backing up our systems (including for disaster recovery purposes) and enhancing the overall security of the Digital Services.
  • Complying with and enforcing applicable legal requirements (including legal process such as court orders, warrants, regulatory investigations, or subpoenas) and/or fulfilling contractual obligations.
  • Providing alerts. We will use your information to send you alerts where “Alerts” are part of the Digital Service you askus to provide e.g.web-monitoring when we find your personal details are available to others online; where there are certain changes to your credit report.

Legal basis for using the information

We must have a legal basis to process your personal information. The legal basis will be one of the following:

  • To honor our contractual obligations to you when we use your information to provide you with the Digital Services or to provide access or a subscription to Materials. For example, when you purchase a subscription from us, it will be necessary to process your payment details and contact details to confirm and provide the subscription. Similarly, when you sign up for a mobile app, we will need to process your registration information so that we can set up your user account and provide the relevant services to you. Failure to provide the information could prevent or delay the fulfillment of the contractual obligations.

Further on, to honor our contractual obligations to you, we need you to give us the information you provide, and to collect information about you from the credit reference agencies or other third parties in order for us to provide you with our Digital Services as agreed in our contract with you. We cannot provide our Digital Services to you without collecting the information you give us because we need certain information from you to be able to create your credit report and score and to show suitable financial offers to you.

For other types of information (such as the information we collect based on your use of the website and information we receive from our sources about you), we process this information for the purposes of providing our services to you as agreed in our contract and for the purpose of to enable us to:

  • provide a secure website to our customers; and
  • analyse our users’ behaviour and preferences, and information collected fromusers’ devices in order to have information required to be able to improve the services we provide to our customers and the user experience on our website.
  • To comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights. We are required to collect certain information from you when processing your subscription payment for tax or financial reporting reasons. Similarly, local tax law will often require us to keep information about contest or promotion participants for audit and taxation purposes.
  • To meet our legitimate interests when we use your information to provide you with the Digital Services, to communicate with you and for advertising and marketing purposes, including interest-based advertising or when we share your information with our affiliates and subsidiaries, in the context of a corporate transaction or with our business partners, social media platforms and advertisers. Our legitimate interests include improving the Digital Services, our products and services, understanding how you interact with our Digital Services and publications, deriving knowledge to develop new products and services, and customizing the Digital Services by making them more relevant and interesting to you and others. When we process personal information to meet our legitimate interests, we put in place safeguards to help ensure that your privacy is given due regard.
  • We will obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to sharing of your information with third parties for their own marketing activities). If we ask for your consent to process your personal information, you can withdraw your consent at any time by contacting us using the details provided in the “Contact us” section of this Privacy Policy further below.

 Information on our use of cookies and similar technologies

Our Digital Services use Cookies and Similar Technologies to provide our Services, to understand how our Services are used and for advertising purposes as explained in this Privacy Policy. You can read more about the types of Cookies and Similar Technologies we use, why we use them and how you can exercise your choices in our Cookie Policy.

 4. How we share the information

VERGE shares the information we obtain with:

Affiliates and Subsidiaries. We currently have no affiliate companies or subsidiaries but if we acquire majority or minority stakes in other companies or if we establish subsidiaries of VERGE, then we will share your information within the VERGE family of companies for example, we may share your browsing and subscription history on our website with other VERGE companies for marketing purposes and internal reporting.

  1. Corporate Subscribers. With respect to corporate subscriptions or memberships, we share your information with the organization that purchased the subscription or membership.
  2. Advertising- and Marketing-Related Service Providers. We may provide your information to entities that create, deliver and assess our advertising or marketing campaigns (irrespective of whether such campaigns are hosted by us).
  3. Social Media Platforms. If you interact with social media widgets on the Digital Services, or share the Materials using social media share buttons, social media platforms may collect information. VERGE does not control this sharing and is not responsible for the privacy practices of the social media platforms with which you engage.
  4. Other Parties When Required by Law or As Necessary to Protect Our Rights. We share your information as and when we believe it necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the Digital Services or other individuals and entities, or to comply with or enforce applicable law or legal process, including responding to court orders, warrants, regulatory investigations, subpoenas and other requests from public and government authorities. We may also provide your personal information to third-party service providers, who provide services to us, including but not limited to, data analysis, order fulfillment, payment processing, and other services.
  5. Strategic Partners and Co-Branded Sites. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with VERGE to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”). These special relationships may include co-branded web sites (“co-branded pages”). Any information, including personal data, that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages, will be shared with our third-party partners. You should check these third parties’ web sites for information regarding their privacy practices. PLEASE NOTE THAT THIS PRIVACY STATEMENT DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want personal data about you shared with such third parties, please do not provide such data in connection with the Jointly Offered Items and/or co-branded pages.
  6. T. If you subscribe to a VERGE Digital Service that contains third-party data, we may be required to provide your personal information to the third party as part of our reporting obligations. We will only do so if a third-party data provider conditions your receipt of their data on knowing your identity.
  7. H. Corporate Transactions. We reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation.
  8. I. With Your Consent or Otherwise at Your Direction. In addition, we share your information with third parties when you consent to or request such sharing.

Because we operate as part of a global business, the recipients referred to above will sometimes be located outside the jurisdiction in which you are located (or in which we provide the Digital Services). See the section on “International Data Transfer” below for more information.

Your rights over your personal information

In certain circumstances, you have a right to access or object to the use of personal information held about you (including in relation to direct marketing and interest-based advertising). You can also ask us to rectify, update, erase, restrict or to share your information in a usable format with another company. Such requests are subject to applicable law.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

If you would like to discuss or exercise such rights, please contact us using the details provided in the “Contact Us” section below. We will contact you if we need additional information from you in order to honor your requests.

5. Your choices, including opt-outs

Direct Marketing Opt-Outs

You may opt out of receiving marketing or promotional emails from us by clicking on the “unsubscribe” or “Preference Center” links contained in such emails. Depending on the Digital Service you use, you may also be able to opt out of marketing or promotional emails by logging into your account and managing your email preferences. Please keep in mind that if you opt out of receiving marketing or promotional emails we will still send you transactional emails or other communications relating to your use of the Digital Services or Materials (e.g., to confirm your access to the relevant Materials, to inform you of changes to a Digital Service or in response to your password recovery request). You may request that we stop sending you direct mail marketing communications by notifying by email at [email protected]apital

6. Do Not Track

VERGE does not currently take steps to respond to browsers “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.

VERGE receives information about you from third-party media database providers. These suppliers provide us with information including your contact details, business organization and coverage beat(s) so that we can send you VERGE content that reflects your interests.

7. How we protect and store your information

VERGE uses a variety of security technologies and procedures to help protect information from unauthorized access, use or disclosure. However, please be aware that no security measure is perfect or impenetrable. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If you register an account on the Digital Services, you are responsible for keeping your password secure. Do not share your login credentials with others.

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

  • Maintain business records for analysis, understanding market trends and/or audit purposes and to improve our Digital Services.
  • Comply with record retention requirements under applicable laws or other relevant legal or regulatory requirements.
  • Defend, establish, exercise or bring any existing or potential legal claims.
  • Carry out fraud detection and prevention.
  • Deal with any complaints regarding the Digital Services, our products and services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.

 Data Integrity

VERGE will use personal information only in ways that are compatible with the purposes for which it was collected, authorized by this Privacy Policy, or authorized by you. VERGE will take reasonable steps to ensure that your personal information is relevant to its intended use, and is accurate, complete, and current (as provided by you). VERGE depends on you to update or correct your personal information whenever necessary.

Cross Border Transfer of personal information

Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information .

If you are located in the European Economic Area (“EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available on the EU Commission’s adequacy list online at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your personal information.

8. Children’s privacy rights

The Digital Services are not intended for use by children, especially those under the age of 13, and we do not knowingly collect personal information from children under the age of 13.

9. Third-party websites, mobile apps or other services

We are not responsible for the privacy practices of any non-VERGE operated websites, mobile apps or other services and channels, and we encourage you to review the privacy policies or notices published by relevant third parties.

This site may contain links to other Internet web sites, including social media sites and third-party hosted collaboration tools. These linked sites are not under VERGE control. We provide links only as a convenience, and VERGE does not endorse or control, and is not responsible for, the privacy practices or the content of these linked sites. If you provide any personal information through any third-party web site, or choose to communicate with us using third-party collaboration tools or other social media platforms, your transaction will occur on that third party’s web site (not our site) and the personal information you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES THAT DO NOT POST OR LINK DIRECTLY TO THIS PRIVACY POLICY.

10. Dispute resolultion

Any dispute concerning the Digital Services (including our use of your personal information) will be resolved per the dispute resolution provision in the Terms of Use, which govern your use of the Digital Services. Please spend some reasonabe time to read the Terms of Use before using the Digital Services.

11. Changes to this privacy policy

We will update this Privacy Policy from time to time to reflect changes in our privacy practices or applicable laws. In accordance with applicable law, we may make such changes without prior notice. We will publish the updated version on the relevant Digital Services and indicate at the top of the Privacy Policy when it was most recently updated. Your use of the Digital Services will be governed by the then-current version of the Privacy Policy. Where changes to this Privacy Policy have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you and where required by applicable law, we will give you advanced notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).

12. Contact us

If you have any questions about this Privacy Policy, please contact us by email at [email protected]  and mark the subject heading of your e-mail “Privacy Policy Inquiry”.

We are committed to working with you to obtain a fair resolution in the event you have a complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to a data protection authority.