What personal information do we collect about you?
We may collect personal informationfrom you in the course of our business, including through your use of our Website,by our useof cookies, and when you contact or request information from us. Much of that data comprises business information, but some of that data may inevitably comprise your personal information. The personal information we may collect and use includes:
How we obtain your personal information
We collect information or data from you in various ways, including:
How we use your personal information
We collect and use data collected from you (however collected), including any personal information, for the following legitimate business purposes of Vincent:
You may use the Website without providing us with your personal information. However, some features on the Website allow you to provide us voluntarily with personal information. If the provision of your personal information is mandatory for a specified purpose, we will let you know that this is the case and inform you of the consequences of failure to provide such personal information.
In order to subscribe to a newsletter or attend events hosted by us, such as webcasts, the following information maybe required: first name; last name; email address; company name, title, city and country. If the required data is not supplied,the newsletter or events will not be made available to you.
Meetings, events and seminars
We will collect and process personal information about you in relation to your attendance at an event or seminar organized by Vincent or its business partners. We will only process and usespecial categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with IT and other service providers or business partners involved in organizing or hosting the relevant event.
We collect, create, hold and usepersonal information in the course of and in connection with the services weprovide to our users. We will process identification and background informationas part of our business acceptance, finance, administration and marketingprocesses, including anti-money laundering, reputational and financial checks.We may also process personal information provided to us by you or on your behalffor the purposes of providing our products or services to you. The informationmay be disclosed to third parties to the extent we think it is reasonablynecessary in connection with provision of our products or service. Please alsosee “Who we share your personal information with” and “Which countries wetransfer your personal information to” below.
Marketing and related communications
If you have already signed up orsubscribed to receive materials from us, we may use your personal informationin order to send you electronic materials relating to Vincent or alternativeinvestments, our newsletters and other products and services and to updaterecords held by us. If you are not already signed up or subscribed to receive informationor materials from us and wish to do so, or if you wish to subscribe toadditional publications, please sign up here using this link.
You may withdraw your consent to thereceipt of materials or newsletters at any time and free of charge by clickingon the “unsubscribe” link in the email, or by sending an e-mail to firstname.lastname@example.org.
Vincent may in the future re-organize or transfer all or part of its business which may result in the transfer of your personal information to new entities (which will be subsidiaries or affiliates of Vincent) or third parties through which the whole or part of the business of Vincent will be carried out. If Vincent ceases to trade, or becomes insolvent, enters into receivership or any similar or equivalent event occurs, those acting on behalf of Vincent may sell the business or partsof it to a third party, in fulfillment of legal or business requirements. This may result in the transfer of your personal information to a third party through which the business or parts of it will be carried out.
On what basis we use your personal information
We use your personal information onthe following bases:
How long we keep your personal information
Vincent endeavors to ensure thatpersonal information is kept up-to-date and that irrelevant, excessive orout-of-date personal information is updated or deleted. To determine theappropriate retention period for your personal information, we will considerthe amount, nature and sensitivity of the personal information, the potentialrisk of harm from unauthorized use or disclosure of your personal information,the purposes for which we process the personal information and whether we canachieve such purposes through other means, the applicable legal and regulatoryrequirements (including requirements to retain the personal information for aminimum period), limitation periods for taking legal action, good practice and Vincent’sbusiness purposes.
Who we share yourpersonal information with
Sharing data to third parties
Personal information may be shared with other non-affiliated third parties, including:
Vincent may use social media sites such as Facebook, LinkedIn and X (formerly known as Twitter). If you use these services, you should review their privacy policies for more information on how they deal with your personal information.
We may share or otherwise makepersonal information available to our affiliates and subsidiaries forcommercial use in their business activities and operations.
We will not sell, rent, distribute orotherwise make personal information commercially available to any third partyexcept with your prior permission.
How we protect yourpersonal information
We use a variety of technical and organizational measures to help protect your personal information from unauthorized access, use, disclosure, alteration or destruction consistent with applicable data protection laws.
Which countries we transfer your personal information to
International transfers tothird parties
Some of the third parties to whom wemay transfer your personal information for the purposes described above may belocated in countries or territories which are outside your local jurisdictionand specifically outside the EEA and the United Kingdom. The data protectionand privacy laws in those jurisdictions may not provide for the same level ofprotection of your personal information as exists in your home country or inthe EEA.
Security of electroniccommunications
Please note that any electroniccommunication made between you and us, including via the Website, may not besecure. While we welcome you to contact us, please do not send us anyelectronic communication that contains any confidential or sensitive personalinformation or data.
Your rights regardingyour personal information
Subject to the provisions of locallaws and regulations from time to time, you may be entitled:
You may also have the right to lodge a complaint in relation to Vincent’s processing of your personal information witha local supervisory authority.
Last Updated: November, 2023
The CPRA Notice describes the types and categories of personal information we collect, the business purposes for which we collect, use and disclose your personal information and your rights in personal information under the CCPA. We do not share your personal information with third party advertisers for cross context behavioral advertising within the meaning of the CPRA. We do not sell your personal information. We may disclose your personal information, but such disclosures are limited to our service providers and contractors, except where disclosure is required by law, court rules, or applicable rules of professional responsibility to a third party or you provide consent for such disclosure.
For purposes of this CPRA Notice, werefer to personal information according to the following definition given inthe CPRA: “personal information” means information that identifies, relates to,describes, is reasonably capable of being associated with, or could reasonablybe linked, directly or indirectly, with a California resident or household.Personal information does not include publicly available information,information that is de-identified or aggregate consumer information, orinformation or rights that are outside the scope of the CPRA. By accessing our Website,using our services or submitting personal information to us, you consent to thecollection, use and disclosure of such information as set forth in this CPRANotice, as it may be updated from time to time.
What categories ofpersonal information do we collect about you?
The categories of personal information we may collect and use includes:
In the past twelve (12) months, depending on the individual circumstances, we may have collected the following categories of personal information: [A-F].
We do not collect sensitive personal information for purposes of inferring characteristics.
Our business reasons for collecting and using your personal information
Depending on the individual circumstances, we collect and use personal information collected from you(however collected), including any personal information, for the legitimate business purposes of Vincent as set forth above. See the sections: How We UseYour Personal Information, Subscriptions to newsletters, Meetings, events and seminars, Other services, Marketing, Business re-organization, and Use ofCookies.
What are our categories of sources of personal information
Vincent collects personal informationfrom the following categories of sources:
Who we disclose yourpersonal information to
We do not “sell” your personal information to, or “share” your personal information with third parties within the meanings of those terms under the CPRA.
In some instances, we may retain other companies and individuals to perform functions on our behalf as “service providers” or “contractors” within the meanings of those terms under the CPRA, including, but not limited to, Information Technology and software providers, website analytics providers and web hosting platforms. Such service providers or contractors may be provided with access to your personal information to perform the functions for which they have been retained.
We will not disclose personal information commercially to any “third party” within the meaning of this term under the CPRA except with your prior permission or where required by law, court rules, or applicable rules of professional responsibility. See the section: Transfers of data to third parties.
In the past twelve (12) months, depending on the individual circumstances, we have not disclosed the categories of personal information collected in Categories [A-F] with outside organizations or entities who are not service providers or contractors providing services on our behalf, except where required by law, court rules or applicable rules of professional responsibility, including but not limited to disclosures that may be permitted or required under rules of civil or criminal procedure. In such circumstances, we have disclosed personal information to the following third parties: courts, regulators, law enforcement and opposing parties among others.
Your rights regarding your personal information
Under the California Privacy RightsAct, you have the following rights in personal information held by us:
You may submit verifiable requests concerning any of your rights by contacting us by e-mail to: email@example.com or by mail at the address below. We will use reasonable methods for verifying that the person making a request to know, data portability, request to corrector a request to delete is the individual about whom we have collected personal information.
This may involve, depending on the nature of the request, confirming that the email address provided corresponds with our records concerning the individual. Additional reasonable measures may also be required to verify the identity of the person making the request depending on the circumstances. For requests to delete made electronically, youmay be required to submit the request to delete, and then separately confirm that you want your personal information deleted. We will maintain a record of your request to delete. To the extent that you wish to use an authorized agent to make requests concerning the rights set forth above, you will need to provide us either with a power of attorney or, alternatively, with signed authorization to communicate with your authorized agent, and directly confirm that you provided the authorized agent with permission to submit the request.
We will (i) confirm receipt of requests to know, data portability, to correct inaccurate information or to delete within ten (10) business days of the request; and (ii) generally respond to requests to know, data portability, to correct inaccurate information or to delete within forty-five  calendar days of the request. If we need additional time to respond to your request beyond the forty-five  calendar days, we will provide you with notice explaining the reasons we need more time, and we will then take up to an additional forty-five (45) calendar days to respond to your request.
Access by persons with disabilities
Persons with disabilities who need assistance accessing this CCPA Notice may contact us as provided for above, and depending on your individual needs, Vincent will grant reasonable requests to furnish this policy in an alternative format.
We do not knowingly collect PersonalInformation from children under the age of 13. We do not sell any personal information, including the personal information of minors under 16 years ofage.
NOTICE TO Nevada Residents
We do not sell your personal information to third parties, regardless of the state in which you reside. However, we are required to give this notice to Nevada residents: If you are a resident of Nevada, you have the right to opt-out of the sale of personal information to third parties. You can exercise this right by contacting us at firstname.lastname@example.org the subject line “Nevada Do Not Sell Request” and providing us with your name and email address.
We may collect data that may include your personal information by sending “cookies” to your browser, which will store them in your device (e.g., computer, phone, etc.) in order to facilitate your browsing.
A cookie is a small chunk of information sent by our web server to the web browser software that you are using to access the Website. A cookie enables our web server to collect information from your web browser software.
We use the following types of cookies:
The data collected through cookies placed on your device will not be kept for longer than is necessary to fulfil the purposes mentioned above; in particular, cookies that we place automatically expire in accordance with the timeframes described above.
You can also change your cookie settings on your browser to block the recording of cookies on your hard drive, in order to minimize the amount of data that may be collected about your navigating on the Website. The procedure for blocking cookies may vary ford ifferent software products. Please check your Internet browser software or with your software supplier if you wish to block cookies. However, disabling cookies may result in certain features of the Website not working, so for optimal use of the Website, we recommend that you do not disable cookies on your device.