Privacy Policy

Last Updated: January 2026

Virdaris Limited is committed to protecting the privacy and security of your personal information and we will always treat you and your personal information with the respect you deserve and are entitled to.

This Privacy Notice sets out how we collect, use, store and disclose the personal information relating to you and your rights about personal information that we hold about you.

Data subjects in the European Union (or any jurisdiction with equivalent legislation to the EU General Data Protection Regulation 2016/679) have certain rights in respect of their personal information. These rights have effect in Jersey to the extent provided by the Data Protection (Jersey) Law 2018 and the Data Protection Authority (Jersey) Law 2018 (and any amendment to, extension, supplement, consolidation or replacement thereof from time to time).

The information we collect about you

Personal individual information (Personal Information) means any information about an individual from which that person can be identified. This includes but is not limited to, name, address, date of birth, gender and national identity or passport numbers, information regarding occupation and previous experience and anti-money laundering and sanctions-related information. It does not include data where the identity has been removed (anonymous data).

The types of Personal Information we may collect and process includes contact details (including (but not limited to) names, postal addresses, email addresses and telephone numbers), Personal Information required to meet our legal and regulatory requirements, in particular in respect of anti-money laundering legislation, including information on source of funds and source of wealth, Personal Information provided in the course of the provision of professional services (for example, information on professional relationships and background, financial wealth and assets held, transactions entered into, tax status, disputes and court proceedings engaged in), in certain circumstances, your and others’ signature(s), financial information such as bank account details and payment related information, the content of any enquiry submitted over our website and any other Personal Information you may provide to us.

We may also collect and process Personal Information regarding people connected to you, either by way of professional (or other) association or by way of family relationship.

We may also collect, store and use “special categories” of more sensitive Personal Information, referred to further below, which require a higher level of protection.

If you apply for a position with Virdaris we may collect Personal Information relating to your past employment, professional qualifications and education, your nationality, immigration and/or residential status, opinions and references from third parties about you and other details about you during the recruitment process.

How personal information is collected

We collect Personal Information either directly from you, in the course of our relationship with you or from third parties, providers of independent or background checks, third parties who we work closely with (including, for example, business partners, sub-contractors or service providers in technical, payment and delivery services, advertising networks, analytics providers and search information providers) or who are connected to you (for example, another service provider who provides services to you) or from publicly available material.

No Personal Information is collected about general visitors to our website. However, in addition to the information collected by us in accordance with this Privacy Notice, your browser supplies some basic information about your visit. The collection of this information is common practice and is used to analyse and understand how our website is being used. The following information may be logged: IP address (the internet address of your computer), date and time of your visit, the type of computer, browser and operating system you are using, the URL's of websites that referred you to our website and the path you take through our website. Please refer to our Cookie Policy for more information.

By using our website, otherwise contacting us, obtaining services from us or by providing your Personal Information to us via the contact options on our website, you acknowledge that you have read and understood this Privacy Notice.

When we will use your personal information

We process Personal Information to provide and improve our services, to comply with our legal and regulatory obligations, to conduct administrative or operational processes within our business, to manage you, third parties and other business relationships, to perform a contract which we may have with you, to establish, exercise or defend our legal rights or for the purpose of legal proceedings, to process and respond to requests, enquiries or complaints received from you or someone connected to you, for engaging other service providers to provide services to you and for other legitimate business purposes.

For each of the purposes for which we process Personal Information, we rely on one or more of the following legal bases:

  • to perform a contract to which you are a party or take steps at your request with a view to entering into a contract;
  • to pursue our legitimate interests or those of a third party (provided your interests and fundamental rights do not override those interests);
  • to allow us to comply with a legal obligation;
  • where necessary for legal proceedings, obtaining legal advice or establishing, exercising or defending legal rights; and
  • where there is no other legal justification available to us, with your consent.

Failure to provide personal information

If you fail to provide certain Personal Information when requested, we may be prevented from complying with our legal obligations, managing our operations effectively or receiving the services provided by you and your organisation.

Sensitive personal information

“Special categories” of particularly sensitive Personal Information require higher levels of protection. These categories include Personal Information on a person's race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data processed for the purpose of uniquely identifying a natural person, health data, data on a person's sex life or sexual orientation or data relating to a person's criminal record or alleged criminal activity.

We may process such special categories of Personal Information where we need to carry out our legal obligations or in connection with legal proceedings, obtaining legal advice or defending legal rights. We may also process such information in the course of legitimate business activities with the appropriate lawful safeguards.

Your duty to inform us of changes

It is important that the Personal Information we hold about you is accurate and current, so please let us know if any of your Personal Information changes (including your correspondence details). Failure to provide accurate Personal Information or to update Personal Information when it changes may have a detrimental impact upon our ability to provide services to you.

Disclosure/sharing of personal information

To the extent permitted by law, we may share your Personal Information with third parties (and their respective employees, directors and officers) including third-party service providers (including, without limitation, information technology and communications service providers, auditors, consultants, insurers, providers of background checks and business risk screening, third parties for marketing or business development purposes), other professional advisers, agents, government institutions, counterparties to transactions or third parties providing services in relation to any matter on which we have been instructed, third parties in the context of a possible sale or restructuring of our business and other members or associates of your organisation.

There may also be circumstances where we are obliged by law to disclose Personal Information, including to law enforcement agencies and applicable regulators, registrars of a public registry where the Personal Information is to be held in a public registry.

Personal Information will be disclosed and/or shared in accordance with the processing grounds set out above. This includes where required by law, where it is necessary to administer the relationship with you, or where we have another legitimate interest in doing so.

Where we share your Personal Information, whether internally or externally, we will ensure that the sharing of such Personal Information is kept to the minimum necessary.

Where we enter into an arrangement with a third party pursuant to which Personal Information may be processed by that third party, we will seek to enter into an agreement with that third party setting out the respective obligations of each party and to ensure so far as possible that the third party has measures in place to protect such Personal Information against unauthorised or accidental use, access, disclosure, damage, loss or destruction.

Transfer of personal information outside of the EU

If we transfer Personal Information from one jurisdiction to another, we will ensure that prior to carrying out the transfer the third-party recipient meets the relevant data protection requirements applicable to the Personal Information being transferred. This may include only transferring the Personal Information where we are satisfied that the recipient has agreed through contract to protect the Personal Information in accordance with the data protection legislation applicable to the Personal Information being transferred, the jurisdiction to which the

Personal Information is being transferred having data protection laws similar to those applicable to the Personal Information being transferred, we have obtained your consent or, if transferred to the United States of America, the transfer will be to organisations that are part of the Privacy Shield.

Retention of personal information

We and the third parties to whom any Personal Information is transferred will retain that information only as long as is necessary for the purposes set out above, where we consider it necessary for the safeguarding of our legitimate interests, to comply with our legal or regulatory obligations or to facilitate our on-going administration and performance.

Subject to the exceptions above, our policy is to retain Personal Information for at least 10 years from termination of our engagement with you.

We will ensure that the Personal Information we hold is subject to appropriate and reasonable security measures.

Your rights

Your rights in connection with Personal Information

Under certain circumstances, by law you have the right to:

  • Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
  • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate Personal Information we hold about you corrected.
  • Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have exercised your right to object to processing (see below).
  • Object to processing of your Personal Information where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes.
  • Request the restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Information to another party.

Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and/or transfer of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

Complaints & questions

If you have any questions about this Privacy Notice or your rights in relation to how we handle your Personal Information, please contact enquiries@virdaris.com. If we have breached our duty of care, we will take appropriate action.

You also have the right to make a complaint at any time to the Jersey Office of the Information Commissioner (https://oicjersey.org).

Changes to this privacy notice

We reserve the right to update this Privacy Notice at any time and any updates will appear on our website (www.virdaris.com). We may also notify you in other ways from time to time about the processing of your Personal Information.