This Notice describes our practices when using:

The personal information of individuals based in the European Economic Area (EEA) or individuals outside the EEA to whom our group companies offer our services, including but not limited to individuals who have interaction with Vanilla Equity or Snaell Capital on web pages and social media sites.

Data Protection laws say that we are allowed to use personal information (including sharing such information with third parties) where we have a proper reason to do so.

Accordingly, we must have one or more of the following reasons:

• To fulfil a contract we have with you;
• When it is our legal duty;
• When it is in our legitimate interest*;
• When you consent to it.

(*) Our legitimate interest is when we have a business or commercial reason to use the information. However, it must not unfairly go against what is right and best for you (more details are available upon request).

In general, we may collect the following types of personal information you give us or through our third parties:

• Identification data, such as name, age/date of birth, place of birth, contact details including address (private and professional), phone number (private and professional), email (private and professional);
• Profession, job title and position;
• Signature;
• Nationality or Civil status;
• Photograph;
• Passport information or other national identification number;
• Tax identification such as National Insurance Number;
• Personal bank account and financial information such as account identification and number, income and (for professional investors) financial licence;
• Information about the account holders’ or investors’ transactions;
• Account history with us;
• Financial details such as fees paid and bank account details;
• Financial licence, dealer number and dealer name;
• “Politically Exposed Person” status, criminal convictions and potentially source of wealth relating to an investment;
• Dealer number and dealer name;
• On Our Website and social media sites, we may collect web activity, cookies information, tracking of engagement;
• Communications including emails, telephone calls, web platform calls and chats, in-person events and webinars, and letters referred to as “Communications” in this notice;

We also collect personal information about users through Our Website, and Vanilla Equity web pages on social media sites such as Twitter and LinkedIn.

Individuals have the following rights, under certain circumstances, in relation to their personal information:

• Right to access personal information
• Right to rectify personal information
• Right to restrict the use of personal information
• Right to request that personal information is erased
• Right to object to processing of personal information
• Right to data portability (in certain specific circumstances)
• Right to lodge a complaint with a supervisory authority.

If you – as an individual – wish to exercise these rights, you can contact us.

A summary of each right and how you can take steps to exercise it is set out below.

Where we receive a request to exercise one of these rights, we shall provide information on the action we take on the request without undue delay and in any event within one month of receipt of the request. This may be extended by a further two months in certain circumstances, for example where requests are complex or numerous.

The information will be provided free of charge, except where requests are manifestly unfounded or excessive, in particular because of their repetitive character. In these circumstances we may charge a reasonable fee or may refuse to act on the request. We will advise you of any fees prior to proceeding with a request.

We may ask for additional information to verify your identity before carrying out a request. If we consider this information insufficient, we reserve the right to reject your request.

Where we do not carry out a request, we shall inform you without delay and within one month of receipt of the request, providing our reasons for not taking the action requested.

Individuals have the right to confirm the following with us:

• Whether or not we process personal information about them
• Certain specified information about the processing

Individuals also have a right to access the personal information and be provided with a copy.

Individuals have the right to request that we restrict processing of their personal information where one of the following applies:

• An individual contests the accuracy of the personal information. The restriction will apply until we have taken steps to verify the accuracy of the personal information;
• The processing is unlawful but an individual does not want the personal information to be erased and requests restriction instead;
• We no longer require the personal information for the purposes of processing, but it is still required by an individual in connection with a legal claim;
• An individual has exercised their right to object to the processing. The restriction will apply until we have taken steps to verify whether we have compelling legitimate grounds to continue processing.

Where personal information is used to target marketing to an individual, they have the right to object to this at any stage.

An individual also has the right to object to processing of their personal information where the legal basis of the processing is in our legitimate interests. We will have to stop processing until we are able to verify that we have compelling legitimate grounds for processing which override the individual’s interests, rights and freedoms, or alternatively that we need to continue processing for the establishment, exercise or defence of legal claims.

If an individual believes that the personal information we hold on them is inaccurate, they may request that it be amended. They may also request that incomplete personal information be completed, including by providing a written confirmation.

An individual may also request the erasure of their personal information in certain circumstances, including the following (this is not an exhaustive list):

• The personal information is no longer necessary in relation to the purposes for which they were collected or otherwise processed;
• The processing was based on consent which has been withdrawn and there is no other legal basis for processing;
• The individual has exercised their right to object to the processing and there are no overriding legitimate grounds for the processing to continue.

There are also certain exceptions where we may refuse a request for erasure, for example, where the personal information is required to comply with a legal obligation or for the establishment, exercise or defence of legal claims.

If an individual does request erasure of their personal information, this will potentially remove records which we hold for their benefit, such as their presence on a suppression list and they will have to contact us to provide personal information if they wish for us to hold this in future.

Where we are relying upon the legal basis either of consent or that the processing is necessary for the performance of a contract to which an individual is a party, and that personal information is processed by automatic means (e.g. electronically), an individual has the right to receive all the personal information which they have provided to us in a structured, commonly used and machine-readable format and to transmit this to another controller directly, where this is technically feasible.

An individual also has a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where they are habitually resident, where they work or where an alleged infringement of Data Protection laws has taken place.

We will keep you up-to-date with details of our products and services through Communications email using the information that you have supplied. When required by regulation and/or law, we will obtain the proper consent to use your contact details, including your email addresses. In any case, you can change your preferences in regards to marketing communications by contacting us.

Additionally, we will ensure that any third party assisting us in marketing our products and services, or with whom we have joint marketing agreements, are under contractual obligations to protect the confidentiality of your personal information, and to use it only to provide the services pertaining to the contract.

We will retain your personal information covered by this Notice for as long as required to perform the purposes for which the data was collected, depending on the legal basis on which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain the personal information. In general terms, this will mean that personal information will be kept for the duration of our relationship and:

• the period required by tax, company and financial services laws and regulations; and
• as long as it is necessary for individuals to be able to bring a claim against us and for us to be able to defend ourselves against any legal claims. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under applicable law.

It may differ from jurisdiction to jurisdiction however, in the majority of cases, this will be during our relationship and then for 10 years after the end of the relationship.

In certain circumstances, data may need to be retained for a longer period of time, for example, where we are in ongoing correspondence or there is a continuing claim or investigation.

As regards information transmitted via the Internet, the Internet is an open system and we cannot and do not guarantee or warrant the security of any information that an individual transmits on or through Our Website or that we otherwise maintain, although Our Website uses the secure file transfer protocol where appropriate.

In certain circumstances, where a client, member or business contact does not provide personal information which is required, we will not be able to provide the products and services under our contract with them or may not be able to comply with a legal obligation on us. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the client or member.

We collect personal information about users through Our Website, and Vanilla Equity and Snaell Capital web pages on social media sites such as Twitter and LinkedIn, including the following:

• Information users provide when they enter information on Our Website, such as when submitting a “Contact Us” message (such as name, email address, salutation);
• Information users provide when they subscribe to email newsletters, press releases or other periodicals through Our Website (such as name, email address, salutation, investor type and country of residence);
• Information users provide when posting content on social media sites;
• Information users provide in their social media bio;
• Information users provide when they respond to a survey or marketing communication, such as their opinions about our services and information about themselves (such as age range, services used, how they know us, their opinions of our services);
• Information users provide when they register for an online account through Our Website (such as name, email address, address, date of birth, unique identification numbers (e.g. client reference number, social security number). The decision to provide this information is optional. However, if the user decides not to provide such information, they may not be able to access certain content or features available on or through Our Website;
• Information captured in our web logs such as device information (e.g. device brand and model, screen dimensions), unique identification numbers (e.g. IP address and device ID), and browser information (e.g. URL, browser type, pages visited, date/time of access);
• Information captured by our cookies (see ‘Cookies, Tags and Similar Technologies’ section below);
• Advertising information (such as size/type of ad, ad impressions, location/format of ad, data about interactions with the ad);
• Behavioral information (such as information on the behavior or presumed interests of individuals which are linked to those individuals and may be used to create a user profile); and
• Information users provide in connection with purchasing items from Our Website shops (such as name, payment card information, and billing and delivery address and purchase details).

Our Websites and online services are for individuals who are at least 18 years of age. Our online services are not designed to be used by minors under the age of 18.

In certain circumstances, where a website user does not provide personal information which is required (for example, in relation to our online services), we will not be able to perform our obligations under the contract with them or may not be able to provide them with products and services. We will make it clear if and when this situation arises and what the consequences of not providing the information will be for the website user.

We use the personal information we collect from Our Website users and individuals accessing Vanilla Equity and Snaell Capital web pages on social media sites for the purposes of:

• personalizing their experience of Our Website;
• monitoring social media content to manage relations with our customers and promote our business and brand;
• if there is an interaction on a social media site with a third party social media user that we consider that we should react on, passing a link to the content and third party’s profile to the department of interest;
• providing products and services that website users have requested;
• administering the website, investigating any complaints and providing customer service;
• providing website users and individuals accessing our web pages on social media sites with information and offers on products or services that may be of interest to them; and
• performing statistical and trend analysis to improve the user experience and performance of Our Website.

Please see below as regards information we collect through cookies and other tracking technologies.

We justify our processing on the following legal bases:

• consent to receiving our marketing communications (see  above section on Marketing Communications), where applicable. In the event that an individual wishes to withdraw their consent they will have an option to “Unsubscribe” or may contact us.
• performing our obligations under our contracts with users buying goods and services from our Webshop or registering online to receive our services or using our online services (subject to our separate terms and conditions of supply);
• compliance with the law or regulatory requirements; and
• pursuing our legitimate interests. A legitimate interest will apply only where we consider that it is not overridden by a website or social media user’s interests or rights which require protection of their personal information.

We have determined that our legitimate interests include the following:

• Promoting our products, services through Our Website and other Communications;
• Monitoring, investigating and reporting any attempts to breach the security of Our Websites;
• Improving the performance and user experience of Our Website;
• Performing our obligations under our contracts with our users;
• Managing our business and brand by monitoring our public profile and responding promptly to complaints;
• Improving the security, performance and user experience of Our Website;
• Targeting personalized marketing to website and social media users for the legitimate purposes of promoting our business and our brand.

Survey Information: Occasionally we may ask users to participate in a brief survey to help us make smart choices as we look for ways to improve Our Website. Information users provide in response to such surveys will not be identified with them unless they consent.

We may disclose personal information of website and social media users to third parties, such as Interactive Brokers.

Our Website may contain links to online websites or content operated and maintained by third parties, over which we have no control. Please consult the privacy policies of these third-party sites to become familiar with their privacy practices and to learn about any choices that these companies may offer you with respect to your personal information.