Privacy Policy

Veranova respects your privacy and is committed to protecting your personal information.

Please read this Privacy Notice carefully as it contains important information to describe your rights under the UK General Data Protection Regulation and Data Protection Act 2018 (“UK GDPR“), the California Consumer Privacy Act (“CCPA”), and the California Privacy Rights Act (“CPRA”) (collectively, UK GDPR, CCPA and CPRA are referred to as the “Data Protection Legislation”) and sets out how we will use and protect your personal information.

We publish the current version of our Privacy Notice on our website, and we will update this from time to time.

We will contact you to notify you of these updates where:

• we are making substantial changes; or
• we are doing something with your personal information which you might not expect based on what we have told you in this Privacy Notice.

Otherwise, any updates to this Privacy Notice will be notified on our website and through our other communications with you.

This Privacy Notice is effective from 1 June 2022, last updated 30 May 2024.

Who are we?

Veranova is made up of different legal entities. This Privacy Notice is issued on behalf of Veranova Parent Holdco, L.P. (US) and its subsidiaries. References to “Veranova”, “we”, “us” or “our” relate to the relevant entity in Veranova responsible for processing your personal information.

For the purposes of applicable Data Protection Legislation, Veranova is the controller of your personal information and responsible for this website, www.veranova.com.

If you have any questions or concerns about the way we treat your personal information, any questions about your rights in relation to your information, or if you would like to request a copy of the personal information we hold about you, please contact us at:

Address:
Head of Data Protection
Veranova
Wheatfield Road
Edinburgh, UK
EH11 2QA
Email: dataprotection@veranova.com
Website: www.veranova.com

You have the right to make a complaint at any time to the relevant government authority. For UK GDPR matters, you may contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

What information do we collect about you?

“Personal information” means information that enables you to be identified, either directly or indirectly.

We may collect, use, store or transfer some or all of the following kinds of personal information about you when you interact with us or from third parties or publicly available sources, such as professional social media (e.g. LinkedIn) or trade directories:

• Behavioural information on your visit to the website: as you interact with our website, we automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data using cookies. Please see the section below entitled Cookies for further information regarding our use of cookies.
• Email address, where you have given your consent to marketing.
• Contact information, including your full name, company name, telephone number and email address, where you have submitted an enquiry via our website contact forms or otherwise provided us with that information.

As a customer, we do not collect any sensitive information about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health or genetic and biometric data) or any information regarding criminal convictions or offences. Where you apply for a job with us, we may process relevant sensitive information (see the Job Applicants section below).

Why, and on what basis, do we use your personal information?

The Data Protection Legislation requires that we have a legal basis on which to process your personal information.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Fulfilling contracts: where we need to perform the contract we are about to or have entered into with you
• Legitimate interest: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests

Where we use personal data for our “legitimate interests”, we have determined, acting reasonably and considering the circumstances, that our legitimate interests are not overridden by your interests, rights, and freedoms, because: (a) we process your information only so far as is necessary for such purpose; and (b) it can be reasonably expected for us to process your information in this way.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. We have set out below a list of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may rely on more than one legal basis for a particular activity depending on the specific use of your data. We often rely on legitimate interests where we use data in a manner that is complementary to but not necessary for performing a contract or a legal duty. Please contact us if you need more information about the specific legal basis we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose	Lawful basis	Legitimate interest
Providing our services
· Following up on contact from you to provide you with information or a quotation relating to our products and services	· Legitimate interest	· Ensuring that we discuss our offering with any potential customers who may wish to receive our products or services
· To enter into and fulfil an agreement with you to provide our products and services	· Fulfilling a contract with you	N/A
· Complying with our regulatory and quality-related obligations	· If responding to and carrying out regulatory product recalls – complying with our legal obligations · In all other circumstances – legitimate interest	· Ensuring that our products are safe and of a consistently high quality
Marketing
· Communicating with you about our products and services	· Legitimate interest	· To allow us to communicate with you in the future to advertise our products and services
Recruitment
· Assessing your skills and employment history to make an assessment regarding your fitness to work at Veranova	· If assessing candidates – legitimate interest · If offering contract of employment – fulfilling a contract · Legal obligations	· To allow us to assess and recruit the most appropriate people to work with us

Marketing

We may use your contact details to communicate with you about any future products and services that we believe will be of interest to you. We will contact you, or businesses associated with you, with marketing messages. We may also contact you if you are a new or existing customer, or you are an existing customer and the marketing messages relate to similar products or services to those that you have currently (or have had in the past), and we have a legitimate interest in doing so.

We may also have regulatory or contractual reasons for sending you communications.

Who do we share your personal information with?

We may share your personal information with the following parties where it is necessary to fulfil the purposes we collected it for:

• Associated entities within the Veranova Group
• External third parties, including:
  • Service providers (acting as processors) who provide IT and system administration services
  • Law enforcement or other authorities where required to do so to comply with a legal or regulatory obligation.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.

International transfers

As an entity with a parent company based in the USA, your data will be transferred outside of the UK or the EEA and to our group entities in the USA as a matter of standard practice. Further, when you contact us in relation to certain products, we will transfer your personal data to the countries in which these products are manufactured to ensure the most appropriate entity responds to your query.

We will take reasonable steps to ensure that your personal information is kept secure and treated in accordance with this Privacy Notice and applicable Data Protection Legislation, including, where relevant, by entering into appropriate contractual terms with the receiving party outside the UK or EEA, such as the Standard Contractual Clauses issued by the ICO or any other approved mechanisms that may become available to us in the future. We will also carry out a risk assessment of the laws and practices of the destination country to identify any technical and organisational measures that need to be put in place to ensure that your personal information is fully protected when in that country.

How do we keep your personal information secure?

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way. We limit access to your personal information to those individuals who have a business need to access it. As part of our security measures, we may sometimes require you to give proof of your identity before we disclose personal information to you.

We regularly monitor our systems for possible vulnerabilities and attacks and carry out tests to identify ways to further strengthen our security. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Third party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

How long do we keep hold of your personal information?

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

Your rights

Under the Data Protection Legislation, you have some important rights. You have the right to:

• Right of access – request details or copies of the personal information we hold about you;
• Right to rectification – request to have your personal information corrected if it is inaccurate, and completed if it is incomplete;
• Right to objection and/or restriction of processing – in certain circumstances, object to or restrict the processing of your personal information;
• Right to erasure – in certain circumstances, request to have your personal information deleted or removed; and
• Right to data portability – in certain circumstances, request to have your personal information that you gave us transferred to you or another organisation.

For further information on each of these rights, including the circumstances in which they apply, see the guidance on individual rights from the ICO or contact us (see Contact section above).

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that your personal information is not disclosed to any other person. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Job applicants

When you apply for a job with us (whether you already work for Veranova or not), we will collect, store and use personal information about you, including information provided in a CV, application form or cover letter, information provided to us during interviews and assessments, records of qualifications, skills and training, references, copies of right to work documentation, and records of pre-employment checks. Some of the information we collect about you may be more sensitive, such as information about your race or ethnic origin, health, or your gender or sexual orientation.

We collect this recruitment information direct from you during the recruitment process and from third parties, including former employers, employment agencies and background check providers.

We use the recruitment information we collect to:

• assess your skills, qualifications, fitness to work and suitability for the work/role;
• carry out background and reference checks, where applicable and where permitted by local laws;
• communicate with you about the recruitment process;
• decide whether to enter into a contract of employment (or other service) with you;
• keep records relating to our hiring processes (which may also be used for diversity monitoring); and
• comply with legal or regulatory requirements.

Subject to local laws, we may retain recruitment information for up to two years after we have communicated to you our decision about whether to appoint you to the role. We may retain your personal information for that period so that we can show, in the event of a legal claim, that we have not discriminated against candidates on prohibited grounds and that we have conducted the recruitment exercise in a fair and transparent way.

How to opt-out of future marketing communications?

You may unsubscribe from future marketing communications by clicking the “Unsubscribe” link at the bottom of any marketing communication that you receive or by submitting a formal request to Veranova at the contact information provided in the “Who are we?” section above.

California Residents: California Privacy Disclosures

California residents who have an established business relationship with Veranova may have the right to request information regarding Veranova’s disclosure of certain personal information to third parties for their direct marketing purposes. To make a request for such information, you may contact Veranova using the contact information in the “Who are we?” section above.

California law entitles California residents to certain rights with regard to their personal information. Those rights have been incorporated into this Privacy Policy under “Your Rights” section above.

California Residents: Does Veranova Sell and/or Share Personal Information?

Veranova does not sell personal information about California consumers that are protected under CCPA or CPRA to third parties or share such personal information with third parties for targeted or cross-context behavioral advertising, as those terms are defined by applicable law. When Veranova permits third parties to collect personal information through our websites or discloses personal information to third parties, Veranova is doing so pursuant to various exceptions to the opt-out rights provided for under California law. For example, Veranova permits third parties acting on its behalf to process personal information for the business purposes described in this Privacy Policy, including advertising and marketing services (excluding cross-context behavioral advertising). In addition, Veranova may permit third-party advertising solutions to process personal information when you direct us to do so by agreeing to the use of such technologies to personalize Veranova’s content and ads. Consistent with the above, Veranova does not sell or share for cross-context behavioral advertising personal relating to consumers who it knows are under 16 years of age.

California Residents: Does Veranova Use or Disclose Sensitive Personal Information?

Veranova does not use or disclose sensitive personal information of California residents except for limited purposes that are authorized by law. For example, Veranova may collect information about a job applicant’s race or gender to comply with EEO regulatory reporting requirements. California law does not afford you rights to limit the use or disclosure of sensitive personal information for these purposes, although we may nonetheless ask for your consent or provide you choices about how we use this information depending on the relevant context.

What are cookies?

Cookies are text files that are placed on your computer or device by websites that you visit. They are widely used to make websites work, to make them work more effectively, and to provide information to the owners of the site.

To find out more about cookies generally, visit www.aboutcookies.org.

Why does this site use cookies?

As is true of most other websites, veranova.com uses cookies to find out information about how visitors are using the website, to make some advanced functionality work (for example, our share price) and to personalise the website experience so it is more relevant to the visitor. These cookies may be delivered in a first-party or third-party context. You have many choices regarding the management of cookies on your computer. All major browsers allow you to block or delete cookies from your system. To learn more about your ability to manage cookies and web beacons, please read ‘how can I manage my cookies’ below.

What cookies does veranova.com use?

This website uses cookies for tracking, improvement and functional purposes.

The primary use of cookies is for Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purposes of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using the Veranova website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

How can I manage my cookies?

Most web browsers allow some control of most cookies through the browser settings, however, please note doing so may mean some elements of this website do not work correctly. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org.

Find out how to manage cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

Every six months we will prompt you to review your cookie preferences, but as a user of our website you have control of these choices and can change them at any time.

This can be done by clicking on the “cookie settings” button below. You can opt-out of each cookie category (except strictly necessary cookies):

Cookie settings