Privacy Policy
| General Data Protection Regulations: | VL Neuberg Holdings Limited and its subsidiaries ("VL Neuberg") are committed to comply with all data protection laws as applicable such as The General Data Protection Regulation in Europe, The Personal Data Ordinance in Hong Kong and all other applicable laws that may fall under our jurisdiction.
The scope of the data protection laws is to guarantee the rights and freedoms of data subjects in relation to their personal data that under the GDPR is defined as: "any information relating to an identified or identifiable natural person (‘data subject'); an identifiable natural personal is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name; an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person". We are required to notify you with the following information regarding the processing of personal data relating to you. |
| Data Protection Officer: | If you would like to contact us with any queries or comments, please contact our Data Protection Officer by using the below contact details:
Bin Lin Guanting Email address: [email protected] |
| Who we are? | The entities of VL Neuberg may be "data controller", "data processor" or "joint controller", as appropriate, regarding one or more specific processing of personal data. A full list of licensed escrows can be found here and a full list of licensed affiliates can be found here. |
| Legal basis of processing: | VL Neuberg will process your data for the following legal basis:
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| Purposes of processing your data: | VL Neuberg will process your data according to the main purpose of the company that is to offer corporate, family office, residency, payroll, accountancy and retirement planning services and other services as agreed with you from time to time.
VL Neuberg will process your data for security reasons, such as due diligence checks, know your client procedures, fraud prevention, anti-money laundering obligations.
VL Neuberg may process your data for direct marketing purpose. |
| Categories of personal data that we collect: | VL Neuberg in the course of its relationship with you will collect the following data about you and, in some circumstances, your spouse, civil partner, partner, beneficiaries or dependants:
VL Neuberg may obtain some of this information from your advisors or agents, if we hold your permission to do so, and from sources available in the public domain. |
| Telephone call recording: | VL Neuberg may have the legal obligation to record telephone calls in certain circumstances, such as the security call to verify the identity of a member, and use a secure telephone call logging software to record, store and archive those telephone
calls.
At certain conditions, recorded voice can be considered health data and as such appropriate safeguards are in place. |
| Consequences of non-provision of your personal data: | In case personal data is necessary to enter into or perform the contract, VL Neuberg would not be able to enter into or continue with its contractual relationship with you. In case personal data is processed according to the legitimate interest of VL Neuberg, you can oppose the legitimate interest at any time, without affecting the contract, especially for marketing purposes, unless exceptions provided by the law apply. |
| Recipients of your personal data: | VL Neuberg shall keep your data confidential and, when disclosed, ensure that third parties shall treat your personal data accordingly. However, from time to time, we may be requested to disclose personal data by law enforcement or to comply
with legal obligations to governmental agencies or entities, regulatory authorities or other persons in line with any applicable law, regulations, court order or official request. For example, your data may be shared with these entities
where VL Neuberg would be expected to cooperate in the event of a criminal investigation.
In any other case, VL Neuberg will share your personal data to execute the contract or related services to:
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| Will your data be transferred inside/outside of the EU? | VL Neuberg may transfer your data outside the European Economic Area and countries that the European Commission has deemed adequate. In such case, the legal tool for international transfer is the standard contractual clauses drafted by the European Commission, a copy of which may be found at the following link: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj?uri=CELEX%3A32021D0914&locale=en |
| How will it be protected whilst in transit? | Data will be encrypted and/or password protected. |
| How long will the data be retained? | VL Neuberg shall retain your personal data for the entire duration of the contractual relationship. After, VL Neuberg shall retain data according to the applicable law, but no longer than what is required by the applicable law or the statute
of limitation for civil liability.
Beyond, the data shall be destroyed or anonymised. |
| Your rights: | Unless legal exemptions apply, you shall have the following rights:
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| Opt-Out from Legitimate Interest: | You have the right to opt-out at any time from legitimate interest-based processing, unless we can demonstrate a compelling legitimate ground (e.g. fraud detection). In case of marketing you have always the right to opt-out. |
| Complaints: | If you wish to lodge a complaint, please contact VL Neuberg's DPO ([email protected]) or, if you prefer to complain to a higher authority, please contact the data protection authority of your residence, place of work or place of the alleged infringement. |
| What about Cookies?
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A HTTP cookie is a small text file that a website stores on your device's browser.
VL Neuberg's website minimises the use of cookies to those strictly necessary, third-party performance cookies (google analytics) and functionality cookies, to personalise your experience offering tailored features. VL Neuberg does not deploy flash cookies or cookies walls. You can choose whether to accept cookies by changing the settings of your browser. Typically, by accessing the browser's help feature you can obtain information on how to prevent your browser from accepting all cookies or to notify you when a cookie is being sent. If you choose not to accept these cookies, your experience at our website and other websites may be diminished and some features may not work as intended.
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| Definitions: | Data Subject is a living individual to whom personal data relates. Processing means any operation or set of operations which is performed on personal data or on sets of personal data. Controller means the natural or legal person, public authority, agency or other body which, alone or jointly with others ("Joint controller"), determines the purposes and means of the processing of personal data. Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; Special categories of personal data means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sexual orientation. |
| Hyperlinks from The VL Neuberg website to external websites: | There may be cases on our website when VL Neuberg provide hyperlinks to other locations or websites on the Internet. These hyperlinks lead to websites published or operated by third parties who are not affiliated with or in any way related
to VL Neuberg. They have been included in our website to enhance your user experience and are presented for information purposes only. We endeavour to select reputable websites and sources of information for your convenience.
However, by providing hyperlinks to an external website or webpage, VL Neuberg shall not be deemed to endorse, recommend, approve, guarantee or introduce any third parties or the services/ products they provide on their websites, or to have any form of co-operation with such third parties and websites unless otherwise stated by VL Neuberg. We are not in any way responsible for the content of any externally linked website or webpage. You use or follow these links at your own risk and VL Neuberg is not responsible for any damages or losses incurred or suffered by you arising out of or in connection with your use of the link. VL Neuberg is not a party to any contractual arrangements entered into between you and the provider of the external website unless otherwise expressly specified or agreed to by VL Neuberg. Any links to websites that contain downloadable software are provided for your convenience only. VL Neuberg are not responsible for any difficulties you may encounter in downloading the software or for any consequences from your doing so. Please remember that the use of any software downloaded from the Internet may be governed by a licence agreement and your failure to observe the terms of such licence agreement may result in an infringement of intellectual property rights of the relevant software provider which we are not in any way responsible. Please be mindful that when you click on a link and leave our website you will be subject to the terms of use and privacy policies of the other website that you are going to visit. |
