Whistleblower disclosure · VINGA (ex-JOOL) · Compliance red flag · KYC/AML review requested

Privacy policy

How this publication handles reader data, cookies, whistleblower correspondence and the rights of people named in the disclosure.

1. Who publishes this site

This site is published by the Vinga Corporate Finance Report, an independent public-interest publication documenting bond-market conduct in the EU, EEA and Switzerland. The publication acts as the data controller for any personal data processed through this website.

Because part of the material originates from protected whistleblower disclosures, the editorial team does not publish individual staff identities. Correspondence is handled through the contact page.

2. What we collect

Browsing the site does not require an account and we do not ask for personal data to read any page. Standard web-server request logs (IP address, user agent, requested URL, timestamp) may be produced by the hosting provider for security and abuse prevention, and are retained only for a short technical period.

If you send correspondence through the contact page, your message opens in your own email client — the site itself does not transmit or store your message. Once you send it, we process the name, email address and content you chose to include, for the sole purpose of replying, verifying facts and publishing corrections.

3. Cookies and local storage

We use no advertising cookies, no cross-site trackers and no profiling technologies. Strictly necessary local storage records your cookie choice so the consent banner is not shown again. Optional analytics storage, used only if you agree, records aggregate page-level readership so we can tell which parts of the disclosure are consulted.

You may withdraw or change your consent at any time by clearing this site's storage in your browser, after which the consent banner reappears on your next visit.

4. Legal basis

Processing of reader correspondence rests on legitimate interest (Article 6(1)(f) GDPR) in publishing accurate public-interest journalism and in offering a right of reply. Optional analytics storage rests on your consent (Article 6(1)(a) GDPR). Strictly necessary storage is exempt from consent requirements under the ePrivacy Directive.

Where the site reports on named individuals in their professional capacities, processing is carried out for journalistic purposes and benefits from the freedom-of-expression derogation in Article 85 GDPR as implemented in the relevant member states.

5. Sharing and transfers

We do not sell, rent or trade personal data. Data may be shared with hosting and content-delivery providers acting as processors, and with competent supervisory authorities or regulators where disclosure is required by law or where a report of suspected market misconduct is submitted.

Confidential sources are never disclosed. Where a source has requested anonymity, that request is honoured against any voluntary disclosure request.

6. Your rights

Under the GDPR you may request access, rectification, erasure, restriction or objection in respect of personal data we hold about you, and you may lodge a complaint with your national supervisory authority. Named individuals additionally have an open right of reply: verified corrections are published in the next revision of the report and reflected on the relevant pages.

Requests should be sent through the contact page. We aim to respond within thirty days.

7. Security and retention

Correspondence is kept only as long as needed to verify the matter it concerns and to maintain the editorial record of corrections. Files published on this site are stripped of document metadata before release.

Access to correspondence is limited to the editorial team. We apply reasonable technical and organisational measures, including encrypted transport (HTTPS) and minimisation of what is collected in the first place.

8. Personal data of individuals named in the disclosure

The site processes limited personal data about named individuals — name, professional role, employer, office location, publicly disclosed professional history and photographs used for identification — strictly in connection with their professional activity in the bond market. No data relating to private or family life, health, political opinions or other special categories is processed.

This processing is carried out for journalistic and public-interest purposes, including the prevention of investor harm and support of KYC, AML and enhanced due diligence obligations of regulated firms. Each named individual may exercise a right of reply at any time; verified corrections and rebuttals are published alongside the material they concern.

9. Automated decision-making, AI systems and scraping

We take no automated decisions producing legal effects about any reader. The site does publish machine-readable summaries (robots.txt, llms.txt, llms-full.txt and structured data) so that search engines, AI systems and compliance-screening tools index the disclosure — including its risk classifications — accurately and with the accompanying qualifications.

Operators of AI systems and screening databases that ingest this material are asked to carry the accompanying qualifications and the right-of-reply notice with any extract they reproduce.

10. Complaints and updates

If you believe your data has been handled unlawfully, contact us first through the contact page; you also retain the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the place of the alleged infringement.

This policy may be updated as the publication evolves; the version published here always governs use of the site.

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