Scope
This Global Privacy Policy for Financial Information (this “policy”) applies to all Velcro Companies’ directors, officers, and employees, as well as contractors, consultants, and anyone authorised to act on Velcro Companies’ behalf. As used in this policy, the “Velcro Companies” or “we” means VIL Ltd and its direct and indirect subsidiaries.
Purpose
The purpose of this policy is to protect the financial information of Velcro Companies’ customers and suppliers (collectively, “you”) and to process such information responsibly and in accordance with law.
Definitions
In this policy, the following terms shall have the following meanings:
- “Financial information” shall mean (a) bank account information; and (b) credit card information.
- “Process” shall mean any operation or set of operations that are performed upon financial information, whether done by automatic means or otherwise making available either by alignment or combination, transfer, storage, restriction, erasure or destruction.
Velcro Companies is the controller of financial information that is provided, stored, processed or otherwise used by or for Velcro Companies, and this means we are responsible for deciding how we hold and use financial information. We recognise the need to treat your financial information in an appropriate and lawful manner, in accordance with all applicable laws. Velcro Companies will provide training, guidance, legal advice, and support for privacy to all employees, to ensure we act in compliance with applicable privacy laws.
Transparency and Data Integrity
- Velcro Companies’ employees may be granted access to financial information of other persons solely for the purpose of furthering their business objectives within the context and constraints under which the information was supplied. Access to the information shall be restricted to those who have a legitimate business reasons to access and use it.
- Velcro Companies’ employees entrusted with such information must actively comply with all company policies on the security, storage, access, control and return or destruction of personal information. Such requirements may appear in other policies.
Security
Velcro Companies shall take appropriate technical and organizational measures against the unauthorised or unlawful processing of financial information and against the accidental loss of, destruction of or damage to financial information. Velcro Companies shall ensure a level of security appropriate to the harm that might result from such unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, and it shall take reasonable steps to ensure compliance with those measures. Employees are responsible to adopt recommended data security best practices, such as encryption, and to follow the data classification policies and standards.
How Financial Information is Used
We will only collect the financial information for legitimate business purposes. We collect financial information of our suppliers for payment purposes. Our banks may need check, wire and ach information for payment purposes. We may also collect bank account information for customers that ask us to direct debit their bank account and credit card information for certain customers that want to pay by credit card. Business credit card numbers are stored temporarily. They are added to an order during order entry and all but the last 4 digits are removed when the credit card is finally charged. (The last four digits are kept to identify which card was used for payment).
Certain members of our finance department, such as those in accounts payable department, have access to this information as part of their job responsibilities.
We only choose trustworthy banking partners to process your financial information who are required to adhere to industry standard policies and procedures for data security.
Non-Compliance
An employee found to have violated this Policy will be subject to disciplinary action, up to and including termination of employment.
Effective Date: October 15, 2023