Website privacy policy

This website is operated by Vista Capital Advisors. We take your privacy very seriously therefore we urge to read this policy very carefully because it contains important information about on:

• Who we are
• How and why we collect, store, use and share personal information
• Your rights in relation to your personal information
• How to contact us and supervisory authorities in the event that you have a complaint.

Who we are

Vista Capital Advisors ('we' or 'us') (trading as Vista) collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data protection Regulations which apply across the European Union (including Luxembourg) and we are responsible as 'controller' of that personal information for the purposes of those laws.

The personal information we collect and use

a) Personal information you provide to us

We collect the following personal information that you provide to us:

• Name
• Surname
• Email

Some examples of when we collect this information include:

• When signing up for our letters
• When creating an account to read the letters

b) Personal information you provide about third parties

If you give us information about another person, you confirm that the other person has appointed you to act on their behalf and agreed that you:

• Shall consent on their behalf to the processing of their personal data;
• Shall receive any data protection notices on their behalf;
• Shall consent on their behalf to the transfer of their personal data abroad.

c) Cookies and similar technologies

A cookie is a small text file which is placed onto your computer or electronic device when you access our website. Similar technologies include web beacons, action tags, local shared objects ('flash cookies') and single-pixel gifs. Such technologies can be used to track users' actions and activities, and to store information about them. We use these cookies and/or similar technologies on this website.

For example we may use cookies to monitor and/or collect the following information:

• How many times a user visits the website;
• Which pages the user visits;
• Traffic data;
• Location data;

This information helps us to build a profile of our users. Some of this information may be aggregated or statistical, which means that we will not be able to identify you individually.

In addition it should be noted that in some cases our cookies or similar technologies may be owned and controlled by third parties who will also collect personal information about you.

On the first occasion that you use our site we will ask whether you consent to our use of cookies. If you do not, cookies will not be used. Thereafter you can opt-out of using cookies at any time or you can set your browser not to accept cookies and the websites below tell you how to remove cookies from your browser. However, some of our website features may not function as a result.

For further information on our use of cookies, please see our Website cookie policy.

For further information on cookies generally visit www.aboutcookies.org or www.allaboutcookies.org.

How we use your personal information

We collect information about our users for the following purposes:

Identify you and manage any accounts you hold with us; process your order; conduct research, statistical analysis and behavioural analysis; carry out customer profiling and analyse your preferences...

Who your information may be shared with

We may share your information with:

• Law enforcement agencies in connection with any investigation to help prevent unlawful activity

We will not share you personal information with any other 3rd parties.

Marketing

We would like to send you information about services and our business which may be of interest to you. Such information could be sent by post, email, telephone, text message or automated call.

We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on purchase, signing up to a newsletter, entering a competition etc). If you do opt in to receive such marketing from us you can opt out at any time (see 'What rights do you have?' below for further information). If you have any queries about how to opt out, or if you are receiving messages you do not want you can contact us using the details provided below.

Whether personal information has to be provided by you, and if so why

No personal information has to be provided by you to us at any time.

How long your personal information will be kept

We will hold your personal information for the following periods:

• Name: deleted as soon as requested
• Email: deleted as soon as requested

These periods are no longer than necessary in each case.

Reasons we can collect and use your personal information

We rely on the following as the lawful basis on which we collect and use your personal information:

Consequence of our use of your personal information

The consequence to you of our use of your personal information is:

• You will be presented with updates of our notes an letters

Keeping your information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised 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 authorised manner and are subject to a duty of confidentiality.

We will also use technological and organisation measures to keep your information secure. These measures may include the following examples:

• User account access is controlled by a unique username and password;
• All data is stored on secure servers

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.

Indeed, while we will use all reasonable efforts to secure your personal data, in using the site you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using the details below.

Transfers of your information out of the EEA

We will not transfer your personal information outside of the EEA at any time.

What rights do you have?

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• Fair processing of information and transparency over how we use your use personal information
• Access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
• Require us to correct any mistakes in your information which we hold
• Require the erasure of personal information concerning you in certain situations
• Receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine readable format and have the right to transmit those data to a third party in certain situations
• Object at any time to processing of personal information concerning you for direct marketing
• Object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• Object in certain other situations to our continued processing of your personal information
• Claim compensation for damages caused by our breach of any data protection laws

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the Luxembourg Information Commissioner's Office (ICO) on individual's rights under the General Data Protection Regulations (http://ico.org.lu/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/)

If you would like to exercise any of these rights please:

• Email, call or write to us
• Let us have enough information to identify you
• Let us know the information to which your request relates

From time to time we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed.

Changes to the privacy policy

This privacy policy was published on 11/12/2020 and last updated on 11/12/2020

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access this website. We will also attempt to notify users of any changes by:

• By email, if you have opted in to receive emails

Contacting us

If you have any questions about this policy or the information we hold about you, please contact us by:

• E-mail: info@vistacapital.be
• Post: Esplanade 1 bus 75 B-1020 Brussel

• ‍

Calls will be answered at the following times:

• Monday to Friday: 9am to 6pm;

Our data protection officer is Gunter Vanden Neucker

‍

‍