Privacy Policy

Introduction

Bhupen Varsani (operating the Varsani Capital platform) (“I”, “me”, or “my”) is committed to protecting your personal data. This Privacy Policy explains how I collect, use, store, and share your information when you use the Varsani Capital platform (the “Platform”), in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Data Controller

Bhupen Varsani (operating the Varsani Capital platform) is the data controller responsible for your personal data.

Data I Collect

I may collect and process the following categories of personal data:

• Identity data: name, username, and title
• Contact data: email address, telephone number, and correspondence address
• Account data: login credentials, account preferences, and security settings
• Technical data: IP address, browser type, operating system, device information, and access timestamps
• Usage data: information about how you use the Platform, including pages viewed and features accessed
• Financial data: portfolio information, transaction history, and investment data you provide to the Platform

How I Use Your Data

I process your personal data on the following lawful bases under Article 6 of the UK GDPR:

• Performance of a contract: to provide and maintain your account, deliver the services you have requested, and manage my relationship with you
• Legitimate interests: to improve the Platform, ensure security, prevent fraud, and conduct internal analytics, where my interests do not override your fundamental rights
• Legal obligation: to comply with applicable laws, regulations, and legal processes
• Consent: where you have given me specific consent to process your data for a particular purpose, such as receiving marketing communications

Data Sharing

I do not sell your personal data. I may share your data with the following categories of recipients:

• Service providers: third-party companies that assist me in operating the Platform, such as hosting providers, analytics services, and email delivery services, bound by contractual obligations to protect your data
• Professional advisers: lawyers, auditors, and insurers where necessary for the provision of their professional services
• Regulatory authorities: where required by law or to comply with a legal obligation

Data Retention

I retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. When determining the appropriate retention period, I consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, and applicable legal requirements.

When your data is no longer required, I will securely delete or anonymise it in accordance with my data retention policies.

Your Rights

Under the UK GDPR, you have the following rights in relation to your personal data:

• Right of access: you may request a copy of the personal data I hold about you
• Right to rectification: you may request correction of inaccurate or incomplete data
• Right to erasure: you may request deletion of your personal data in certain circumstances
• Right to restrict processing: you may request that I limit the processing of your data
• Right to data portability: you may request a copy of your data in a structured, commonly used, machine-readable format
• Right to object: you may object to processing based on legitimate interests or for direct marketing purposes
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing

To exercise any of these rights, please contact me. I will respond to your request within one month.

Cookies

The Platform may use cookies and similar tracking technologies to enhance your experience and collect usage data. Cookies are small text files stored on your device by your browser. I use the following types of cookies:

• Strictly necessary cookies: required for the Platform to function, such as authentication and session management
• Analytical cookies: help me understand how users interact with the Platform, allowing me to improve its functionality and performance

You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

International Transfers

Your data may be transferred to, stored, or processed in countries outside the United Kingdom. Where such transfers occur, I ensure that appropriate safeguards are in place to protect your data, including the use of Standard Contractual Clauses approved by the Secretary of State, or transfers to countries that have been deemed to provide an adequate level of data protection.

Data Security

I implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption of data in transit using TLS, access controls, and regular security assessments. However, no method of transmission over the internet or electronic storage is completely secure, and I cannot guarantee absolute security.

Changes to This Policy

I may update this Privacy Policy from time to time. I will notify you of any material changes by posting the updated policy on the Platform with a revised "Last updated" date. I encourage you to review this policy periodically.

Complaints

If you are unhappy with how I have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK's supervisory authority for data protection. You can contact the ICO at ico.org.uk or by telephone on 0303 123 1113.