Privacy Policy

Last updated: February 1st, 2020


Protecting your personal information is an important priority for Velo Trust. This privacy policy is designed to support this objective and, where applicable, sets out how Velo Trust will process personal information as a Data Controller. Velo Trust collects non-public personal information provided by you or your representative on applications or other forms furnished to Velo Trust or through other interactions that you or your representative have with Velo Trust. We urge you to read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information and on how to contact Velo Trust and supervisory authorities in the event you have a complaint. This Privacy Policy applies to websites owned and operated by Velo Trust as well as all services provided by Velo Trust. References to Velo Trust mean Velo Trust, its agents, successors and assigns.

Velo Trust does not disclose any non-public personal information about you, except as permitted by law. If you decide to close your account, Velo Trust will continue to adhere to the privacy policies and practices as described in this notice.

How and Why We Obtain Information

Velo Trust may receive non-public personal information about you (the “Personal Information”) from any of the following sources:

  • Your applications or forms (for example, name, address, birth date);
  • Transactional activity in your account (for example, trading history and balances);
  • Information from credit reference agencies;
  • Information from other third-party data services (for example, to verify your identity and to better understand your product and service needs);
  • Other sources with your consent or with the consent of your broker;

Velo Trust may process the Personal Information for the following purposes:

  • Managing and administrating any account you may hold with Velo Trust on an on-going basis (the “Services”);
  • Velo Trust will itself (or through a third party e.g. credit reference agency) process certain information about you or your directors, officers and employees and your beneficial owners (if applicable) in order to carry out anti-money laundering (AML) checks and related actions which Velo Trust considers appropriate to meet any legal obligations imposed on Velo Trust relating to, or the processing in the public interest or to pursue Velo Trust’s legitimate interests in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with Velo Trust ‘s AML procedures;
  • to monitor and record calls and electronic communications for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution, and to enforce or defend to report tax related information to tax authorities in order to comply with a legal obligation;
  • to monitor and record calls and electronic communications for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution, and to enforce or defend Velo Trust and its affiliates’ rights, itself or through third parties to whom it delegates such responsibilities or rights in order to comply with a legal obligation imposed on Velo Trust or to pursue Velo Trust’s legitimate interests in relation to such matters or the processing in the public interest;
  • to monitor and record calls for quality, business analysis, training and related purposes in order to pursue the legitimate interests of Velo Trust to improve its service delivery;
  • to retain AML and other records of individuals to assist with subsequent screening of them, including in relation to investment in other funds or the provision of other services by Velo Trust, to pursue Velo Trust’s and (in some circumstances) its clients’ legitimate interests.

How We Protect Information About You

We take reasonable security measures consistent with applicable law to protect the security of your Personal Information from being accidentally lost, or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. We also implement the use of encryption or Secure Socket Layers connections for the transmission of any Personal Information.

We will retain your Personal Information as long as an account is active or as needed to provide you Services. You may, at any time, instruct us to remove Personal Information, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to Velo Trust from our servers. We will also retain your Personal Information as necessary to comply with legal obligations, resolve disputes and enforce our agreements.

How We Share Information About You

We may share the personal information that we collect about our customers, prospects, or former customers with their brokers or:

  • To credit reference agenciesin order to carry out money laundering and identity checks and comply with legal obligations;
  • To competent authorities, courts and bodies as required by law or requested or to affiliated for internal investigations and reporting.

Online Privacy

Privacy, security and service in Velo Trust’s online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques and authentication procedures, among others, to maintain the security of your online session and to protect Velo Trust accounts and systems from unauthorized access.

When you interact with us through online channels (for example, websites and mobile applications) owned and controlled by Velo Trust (“Velo Trust websites”), Velo Trust manages personal information in accordance with all of the practices and safeguards described previously.

When you visit Velo Trust’s websites, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on Velo Trust’s websites. We use this information for a variety of purposes, such as maintaining the security of your online session, facilitating site navigation, improving Velo Trust’s website design and functionality, and personalizing your experience on Velo Trust’s websites. Additionally, the following policies and practices apply when you are online:

Velo Trust provides information to its clients through electronic means only. These include Email, website and online platform. Kindly note that to receive information electronically from Velo Trust, a valid Email address is required. Velo Trust provides information through our website which may not be addressed personally to you.

Cookies and similar technologies

We use cookies and similar technologies to support the operation of Velo Trust websites. Cookies are small amounts of data that a website exchanges with a web browser or application on a visitor’s computer or mobile device. Cookies help us to collect information about visitors to Velo Trust websites, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site. Velo Trust cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.

Protecting children’s privacy online

Velo Trust websites are not directed to individuals under the age of thirteen (18). Velo Trust does not intentionally collect information on Velo Trust websites from those we actually know are under 18, and we request that these individuals do not provide personal information through the sites.

Access to Your Information

You may access and, if necessary, correct your account information through a variety of media offered by Velo Trust for example through email request.

Data Subject Rights

You have the following rights, in certain circumstances, in relation to your personal information:

  • Right to access your personal information.
  • Right to rectify your personal information.
  • Right to restrict the use of your personal information.
  • Right to request that your personal information is erased.
  • Right to object to processing of your personal information.
  • Right to data portability (in certain specific circumstances).

Where you have provided your consent to processing (e.g. to receive information about products and services which may be of interest to you or to the institution you represent), you may withdraw your consent at any time by contacting Velo Trust by email on dataprivacy@velotrust.com

Where Velo Trust requires your personal information to comply with AML or other legal requirements, failure to provide this information means Velo Trust may not be able to provide the Services or the service to the institution you represent.

You have the right to lodge a complaint with a supervisory authority.

How To Complain

We hope that we can resolve any query or concern you raise about our use of your information. You may contact our Privacy Office or your country’s supervisory authority to lodge a complaint.

For questions or concerns about this Privacy Policy or the information we maintain, or to instruct us to remove Personal Information, you may contact Velo Trust on: dataprivacy@velotrust.com