About Vision Blue
Vision Blue was set up in 2021 to advise in relation to the development of a portfolio of strategic metal and mineral assets with the aim of facilitating the global transition to a green economy and away from fossil fuels.
When we say ‘we’, ‘us’, ‘our’ or ‘Vision Blue’, we mean Vision Blue Advisors UK LLP. “You” or “your” refers to you and any person acting on your behalf.
Information we collect
It is in Vision Blue’s legitimate interest to collect information on businesses that may benefit from investment and to continue to develop a relationship with them until such time an investment is made. Thereafter, it remains in our legitimate interest to use information to effectively advise in relation to the performance or exit of portfolio investments.
Vision Blue will collect your information and information relating to individuals connected to your business, in line with relevant regulations and applicable law. It could be collected from a range of sources and may relate to an investment portfolio; proposed new investments (some of which may not be progressed); or any previous investments.
We may also collect information about you and individuals connected to your business when you or they interact with us, e.g. via a telephone call, meetings or email; visiting our website; visiting our office; or via your intermediaries such as banks, corporate finance firms and other advisers. We may supplement this information from publicly available sources, professional data service providers and other appropriate third parties.
Purpose
We collect information for the following purposes:
- Investment activity – investment proposals and supporting papers containing analysis and appropriate due diligence surrounding the suitability of a potential new or follow on investment and monitoring investments. This may include analysis about you and individuals connected to your business including: past, current and future performance assessments; drivers and motivations for obtaining investment; ongoing details regarding share ownership and financial remuneration; and information that may be obtained from third parties (e.g. references)
- For the purposes of compliance, fraud prevention, physical security, other legal and regulatory obligations and pursuing our mutual legitimate interests and legal rights – records of correspondence and other communication between you and your intermediaries and Vision Blue, including email, instant messages, voicemail and records captured through other digital channels. Additionally, we will collect individual information for the purposes of maintaining insider lists in respect of investment activity in regulated markets
Information sharing
We may share your information and information relating to individuals connected to your business with others where lawful to do so (subject to the terms of any confidentiality agreement in place governing such information) where we have:
- a legal or regulatory duty to do so (e.g. preventing fraud and other financial crime, for regulatory reporting including internal and external audit, asserting or defending our legal rights and interests)
- a legitimate business reason for doing so (e.g. to provide investment advice, manage risk, verify identity, enable another company or individual to provide you with services you have requested, assess your suitability for investment, or in order to monitor or exit investments)
- asked you and/or if appropriate the individuals connected to your business for your permission to share it, and you (or they) have agreed
Your information and information relating to individuals connected to your business (subject to the terms of any confidentiality obligations in place governing such information) may be shared with:
- other companies affiliated to Vision Blue and any subcontractors, agents or service providers who work for us or provide services to us or other Vision Blue affiliated companies to the extent reasonable and necessary to do so
- our principal firm under whose regulatory umbrella we operate
- authorised agents, professional advisers and sub-contractors acting for you, your business, or individuals connected to your business
- authorised agents and advisers that provide due diligence and corporate transaction services on our behalf, which may include but are not limited to legal advisers, tax advisers, financial advisers and specialist sector/industry experts
- other financial institutions and tax and other authorities, including the Financial Conduct Authority, National Crime Agency or other such regulatory bodies
- anybody else that we’ve been instructed to share your information with by you, or anybody else who provides instructions or operates any of your investment services on your behalf
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
How long we keep information
Our general retention policy is to keep information for a minimum of seven years although we will keep information for as long as is necessary to fulfil the purposes we collected it for and to comply with our legal and regulatory requirements, therefore we will often extend the seven-year period should we anticipate the need to re-engage with you for similar services as we continue to monitor your business through our customer relationship management and deal flow activities.
We may retain records relating to you and individuals connected to your business for legitimate reasons, for example preventing fraud and financial crime, complying with regulatory requirements, protecting our legal rights and interests, or dealing with complaints.
Where information has been shared with third parties in relation to our investment activity with you or those connected to your business, those third parties may use different retention schedules to ours in line with their own terms, conditions and associated policies.
Transferring information overseas
Your information and information relating to individuals connected to your business may be transferred within the European Economic Area (EEA) and to Guernsey. Information may be transferred outside of this area. Where it is in our own legitimate interests to transfer personal data outside the EEA and Guernsey, we will apply or seek a similar level of protection commensurate with the sensitivity of the personal data.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Your rights
You and individuals connected to your business may have a number of rights in relation to the information that we hold about them. These rights may include:
- the right to access information we hold about them and to obtain information about how we process it
- in some circumstances, the right to restrict, object to or withdraw their consent to our processing of their information, which they can do at any time. We may continue to process their information if we continue to have a legitimate reason for doing so
- in some circumstances, the right to receive certain information they have provided to us in an electronic format and/or request that we transmit it to a third party
- the right to request that we rectify their information if it’s inaccurate or incomplete
- in some circumstances, the right to request that we erase their information. We may continue to retain their information if we continue to have a legitimate reason for doing so
You and individuals connected to your business can exercise their rights by contacting us using the details set out in the “Who to contact for more information” section below. Individuals also have a right to lodge a complaint to the UK Information Commissioner’s Office. Further information can be obtained by visiting www.ico.org.uk.
Who to contact for more information
Due to the limited nature, volume and sensitivity of personal data that we process, we are not required to employ a formal Data Protection Officer. You or individuals connected to your business can obtain further information on anything stated in this Privacy Notice, or can exercise your rights under this notice, by writing to “Compliance” at our registered address.