Privacy Notice

At the Vemi Group, your privacy is important to us. It is the Vemi Group's policy to respect your privacy and comply with applicable laws and regulations relating to privacy and/or the processing of personal information (being any information from which a person can be identified) which we may hold and process about you, including the Data Protection Act 2018, the UK GDPR (as defined in the Data Protection Act 2018), the Privacy and Electronic Communications (EC Directive) Regulations 2003 and all similar or related laws and regulations relating to privacy and/or the processing of personal information applicable to us from time to time ("Data Protection Laws").

This Privacy Notice applies to all personal information which we may hold and process about you as a data controller, including where you: (i) are an investor or prospective investor in the Ethos Group; (ii) provide services to the Ethos Group, have a business dealing with the Ethos Group, or are employed or engaged by an organisation which provides services or has a business dealing with the Ethos Group; (iii) apply for a job with the Ethos Group; or (iv) are the next of kin for a staff member of the Ethos Group.

If you are a staff member of the Ethos Group, your personal information is held and processed by us as a data controller in accordance with the terms of our internal staff privacy notice.

The following entities constitute the "Vemi Group":

• Ethos Invest Limited, a private limited company incorporated in England and Wales with registered company number 12777833 ("Vemi Ventures");

• Ethos (No.1) Limited, a private limited company incorporated in England and Wales with registered company number 15081302 ("Vemi Money"); and

• Ethos Asset Management Limited, a private limited company incorporated in England and Wales with registered company number 13659829 ("Vemi Capital"),

each of which is a separate data controller in respect of personal information.

Unless otherwise specified in this Privacy Notice, the statements made within this Privacy Notice are made by each of Vemi Ventures, Vemi Money and Vemi Capital separately and references to “we”, "us" or “our” in this Privacy Notice should be considered references to each of Vemi Ventures, Vemi Money and Vemi Capital separately.

This policy was last updated on: 18th September 2024

Vemi Ventures may process the following types of personal information about you:

• name
• contact details (including postal address, telephone number, and e-mail address)
• job title / function
• date of birth
• your preferences in receiving marketing information and your communication preferences (where these have been shared by you with Vemi Ventures)
• other personal information which you may share through your interactions with Vemi Ventures (both online (e.g. from communications via websites or email) and offline (e.g. from communications via letter or telephone or in person))

If you consider investing with Vemi Ventures, Vemi Ventures may also process your financial personal information and other personal information necessary for the purposes of carrying out due diligence (such as necessary anti-money laundering checks), including your national insurance number, social security number or tax payer identification number, investment history and bank details.

If you provide services to Vemi Ventures, have a business dealing with Vemi Ventures, or are employed or engaged by an organisation which provides services or has a business dealing with Vemi Ventures, Vemi Ventures may also process your bank account information and other information necessary for processing payments, your employment information and other information necessary for the purposes of carrying out due diligence (such as necessary anti-money laundering checks).

If you apply for a job with Vemi Ventures, Vemi Ventures may also process your personal information in any CVs or references provided to us.

Vemi Money may process the following types of personal information about you:

• name
• contact details (including postal address, telephone number, and e-mail address)
• job title / function
• date of birth
• your preferences in receiving marketing information and your communication preferences (where these have been shared by you with Vemi Money)
• other personal information which you may share through your interactions with Vemi Money (both online (e.g. from communications via websites or email) and offline (e.g. from communications via letter or telephone or in person))

If you consider investing with Vemi Money, Vemi Money may also process your financial personal information and other personal information necessary for the purposes of carrying out due diligence (such as necessary anti-money laundering checks), including your national insurance number, social security number or tax payer identification number, investment history and bank details.

If you provide services to Vemi Money, have a business dealing with Vemi Money, or are employed or engaged by an organisation which provides services or has a business dealing with Vemi Money, Vemi Money may also process your bank account information and other information necessary for processing payments, your employment information and other information necessary for the purposes of carrying out due diligence (such as necessary anti-money laundering checks).

If you apply for a job with Vemi Money, Vemi Money may also process your personal information in any CVs or references provided to us.

Vemi Capital may process the following types of personal information about you:
‍
• name
• contact details (including postal address, telephone number, and
e-mail address)
• job title / function
• date of birth
• your preferences in receiving marketing information and your communication preferences (where these have been shared by you with Vemi Capital)
• other personal information which you may share through your interactions with Vemi Capital (both online (e.g. from communications via websites or email) and offline (e.g. from communications via letter or telephone or in person))

If you consider investing with Vemi Capital, Vemi Capital may also process your financial personal information and other personal information necessary for the purposes of carrying out due diligence (such as necessary anti-money laundering checks), including your national insurance number, social security number or tax payer identification number, investment history and bank details.

If you provide services to Vemi Capital, have a business dealing with Vemi Capital or are employed or engaged by an organisation which provides services or has a business dealing with Vemi Capital, Vemi Capital may also process your bank account information and other information necessary for processing payments, your employment information and other information necessary for the purposes of carrying out due diligence (such as necessary anti-money laundering checks).

If you apply for a job with Vemi Capital, Vemi Capital may also process your personal information in any CVs or references provided to us.

When you visit our website or interact with our services, we may automatically collect data about your device, such as: (i) device type; (ii) operating system; (iii) unique device identifiers;(iv) device settings; and (v) geo-location data. The data collected can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit. Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is. While some of this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

We use "cookies" to collect information about you and your activity across our website. Please refer to our Cookie Policy for more information.

Vemi Ventures may process your personal information to:

• administer any investment you might make
• develop and improve products and/or services
• operate in the ordinary course of business, including for internal record keeping and administrative purposes
• contact and communicate with you
• carry out verification checks and/or due diligence – for example, in relation to anti-money laundering (AML) and know your client (KYC) procedures
• comply with our reporting obligations
• resolve any disputes that we may have
• consider any applications you may submit
• organise and hold events in connection with the business
• protect the security of communications and other systems to prevent and detect security threats, frauds or other criminal or malicious activities
• enable you to access and use the website, associated applications and associated social media platforms• improve the website, associated applications and associated social media platforms
• enable you to customise or personalise your experience of our website• attribute any content (e.g. posts and comments) you submit that are published on the website
• for analytics, market research and business development purposes
• send you marketing communications (where permitted pursuant to the Data Protection Laws)

Vemi Money may process your personal information to:

• administer any investment you might make
• provide you with products and/or services
• develop and improve products and/or services
• operate in the ordinary course of business, including for internal record keeping and administrative purposes
• contact and communicate with you
• carry out verification checks and/or due diligence – for example, in relation to anti-money laundering (AML) and know your client (KYC) procedures
• comply with our reporting obligations
• resolve any disputes that we may have
• consider any applications you may submit
• organise and hold events in connection with the business
• protect the security of communications and other systems to prevent and detect security threats, frauds or other criminal or malicious activities
• enable you to access and use the website, associated applications and associated social media platforms• improve the website, associated applications and associated social media platforms
• enable you to customise or personalise your experience of our website• attribute any content (e.g. posts and comments) you submit that are published on the website
• for analytics, market research and business development purposes
• send you marketing communications (where permitted pursuant to the Data Protection Laws)

Vemi Capital may process your personal information to:

• administer any investment you might make
• provide you with products and/or services
• develop and improve products and/or services
• operate in the ordinary course of business, including for internal record keeping and administrative purposes
• contact and communicate with you
• carry out verification checks and/or due diligence – for example, in relation to anti-money laundering (AML) and know your client (KYC) procedures
• comply with our reporting obligations
• resolve any disputes that we may have
• consider any applications you may submit
• organise and hold events in connection with the business
• protect the security of communications and other systems to prevent and detect security threats, frauds or other criminal or malicious activities
• enable you to access and use the website, associated applications and associated social media platforms• improve the website, associated applications and associated social media platforms
• enable you to customise or personalise your experience of our website• attribute any content (e.g. posts and comments) you submit that are published on the website
• for analytics, market research and business development purposes
• send you marketing communications (where permitted pursuant to the Data Protection Laws)

You may opt out of receiving direct marketing communications from us by following the instructions outlined in any marketing communication or by otherwise contacting us using the contact information set out at the bottom of this Privacy Notice.

Personal information you provide to us directly

You may provide us with your personal information when you:
• carry out a transaction with us; or
• otherwise communicate with us (both online (e.g. via websites or email) and offline (e.g. via letter or telephone or in person).

Personal information may also be automatically sent by your device(s) to us in the course of you accessing our website, products and/or services. Please see the information above under the heading "Device Data, Log Data and Cookies".

Information you provide to us indirectly

We may receive personal information from other entities within the Ethos Group for recruitment or investor relations purposes.

Information from other sources

‍We may supplement the personal information provided to us with information obtained from publicly available sources or research data we receive from other trusted sources. For example, our marketing and market research activities may uncover data and insights, which we may combine with information about how visitors use our website to improve our website and your experience on it.

We may rely on one or more of the following lawful bases to process your personal information from time to time:
‍
‍Legitimate interests

‍We primarily process your personal information on the basis that it is necessary for our legitimate interests in fulfilling the purposes described above and does not unduly impact your rights. Our primary legitimate interest is to build a digital ecosystem of ethical financial service firms that solve the values- and faith-based compromises made by customers while improving their financial wellbeing in the process. We only rely on legitimate interests where we consider that our legitimate interests are not overridden by your interests or fundamental rights or freedoms (for example, we consider any potential impact on you, how intrusive the processing might be from a privacy perspective and your other rights under the Data Protection Laws).

Legal obligation

‍In some circumstances we may process your personal information on the basis that it is necessary for compliance with our legal obligations. Such cases may include (but are not limited to) responding to court orders, criminal investigations, government requests, and regulatory obligations.

‍Perform or enter into a contract with you

‍In some circumstances we may process your personal information on the basis that 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.

‍Consent

‍In limited circumstances and for particular processing activities we may rely on your consent to process your personal information, but we will only do this where you have expressly provided your consent to those specific processing activities. If you have provided your consent to us processing your personal information in a particular way but you later change your mind, you have the right to withdraw such consent at any time by contacting us using the contact information set out at the bottom of this Privacy Notice, however this will not affect any use of your information that has already taken place.

In connection with the purposes described above and where we have a lawful basis to do so, we may share your personal information with:

• other members of the Vemi Group;
• our employees, contractors and/or consultants;
• third-party sub-contractors and/or service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors, and payment systems operators;
• our existing or potential agents or business partners;
• credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you; and
• courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights.

If we or our assets are acquired, we merge with another business, and/or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us or with whom we merge. Any parties who acquire us or our assets, or who merge with us, may continue to use your personal information in accordance with the Data Protection Laws.

When we collect and process your personal information, and while we retain your personal information, we protect it from loss and theft, as well as from unauthorised access, disclosure, copying, use or modification, by implementing and maintaining appropriate technical and organisational security and safeguarding measures pursuant to the Data Protection Laws.

Although we implement and maintain appropriate technical and organisational security and safeguarding measures to protect your personal information, no method of electronic transmission or storage is 100% secure and no one can guarantee absolute data security.

Your personal information will be stored and processed in the United Kingdom, but may also be transferred to, stored at and/or processed in territories outside the United Kingdom. We will only transfer your personal information:

• to recipients in territories that are the subject of an adequacy decision under the Data Protection Laws; or
• to recipients in other countries if we have provided adequate safeguards for your personal information in accordance with the Data Protection Laws (such as through the use of contractual safeguards specified in the Data Protection Laws).

We keep your personal information only for as long as we need to and in any case, only for as long as permitted by the Data Protection Laws. This time period may depend on what we are using your personal information for, in accordance with this Privacy Notice. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you (unless we are permitted to retain such personal information in accordance with the Data Protection Laws, such as for compliance with legal obligations).

In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Notice does not apply to any of your activities after you leave our site.

In certain circumstances and subject to certain exemptions, you have the following rights in relation to the personal information that we hold about you:

·        Your right to be informed – you have the right to ask us for information regarding how we use your personal information.
·        Your right of access - you have the right to ask us to provide copies of your personal information.  
·        Your right to rectification - you have the right to ask us to rectify personal information that you think is inaccurate, or to complete personal information that you think is incomplete. Please ensure that any personal information you provide us with is accurate and complete and you notify us of any changes to your personal information as soon as possible so that we can update our records.
·        Your right to erasure - you have the right to ask us to erase your personal information.
·        Your right to restriction of processing - you have the right to ask us to restrict the processing of your personal information.
·        Your right to data portability – you have the right to ask us to transfer personal information to another data controller.
·        Your right to object to processing - you have the right to object to the processing of your personal information.

You also have rights in relation to any automated decision-making and/or profiling and the right to withdraw consent to any consent-based processing at any time.

If you wish to exercise any of these rights, or if you have any queries or complaints in relation to how we use your personal information, please contact us using the contact information set out at the bottom of this Privacy Notice.

If you wish to take any queries or complaints further, you have the right to contact the appropriate regulator regarding such issues. The Information Commissioner's Office is the appropriate regulator in the UK (https://ico.org.uk/). The regulators across the EU are listed here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

We may update this Privacy Notice from time-to-time, at our sole discretion, effective immediately upon the posting of a new version on our website. Please check this page regularly to ensure you are familiar with the current version.

For any questions or concerns regarding your privacy, you may contact our data protection officer using the following email address: dpo@vemiventures.com.