Information you give to us We may collect and process the following personal information about you:
- General personal details, which may include:
- Any communications between us and our clients whether by telephone, email or otherwise), for example, to report a problem or to submit queries, concerns or comments regarding our services, investment or product updates or general comments.
- Know Your Customer (KYC) documentation, which may include:
Information we receive from others We are also working closely with third parties (including, for example, lawyers, accountants, bankers compliance consultants (and other service providers) and may receive information about you from them.
We use your personal data for the following purposes: Providing our services to you We need to process certain personal information in order to provide our services to you, which includes verifying and maintaining an accurate record of our prospective and current clients.
In order to deliver our services, your personal data may also be transferred to the following third parties:
Contacting you about our services If you have given us your contact information, we may use these details to contact you about the services we offer such as to email you details of future investments, details of which you may be interested in reviewing. You may opt out of this at any time by telling us, or if we have contacted you via email, you will be able to respond to the sender.
Improving our services We may use your personal data to gain insights into how we can improve our products and services. This will not involve sharing your data with third parties.
Customer Support and account administration We may use your personal data to provide you with customer support or to investigate complaints or concerns about our mutual business relationship.
Under Article 6 of the EU General Data Protection Regulation (GDPR) we are required to tell you about the legal basis under which we collect and process your data.
We will only collect and process your personal data in accordance with one of the following lawful bases:
- Performance of a contract: This is where the processing is necessary for a contract we have with you, or you have asked us to take specific steps before entering into a contract, such as determining suitability of a product or client for one or more of our investment projects. This lawful basis covers the following purposes:
- Our legitimate interests: This is where we collect and process data in accordance with our “legitimate interests”. Our legitimate interests include:
- Compliance with our legal obligations: We may be required to process or share your personal data in compliance with a legal obligation. In general, this will involve collecting information for KYC purposes, but we may also need to process your personal data in response to a request from the authorities, or when establishing, maintaining or defending legal claims.
We take the security of your data very seriously, and all of your personal data will be kept according to strict safeguards and in compliance with the GDPR. Your data will be stored securely on servers within the EEA and we will only store your data outside the EEA in the event that the jurisdiction in question has been assessed as compliant with the GDPR.
You have the right to be informed over what personal data we hold and how we are using it. This information is contained within this privacy notice.
If you have consented to particular uses of your personal data, you have the right to withdraw this consent at any time.
You may request a copy of the personal data we hold on you at any time. This information will be provided to you in digital format and free of charge unless we consider your request manifestly unfounded or excessive.
Where we are using your personal data in accordance with our legitimate interests, you can object to further use of your data. This objection should be based on grounds relating to your particular situation. If you object, we will stop using your personal data in this way immediately, unless there are compelling legitimate grounds for processing your personal data which override your interests, rights and freedoms (such as requests by law enforcement) or we need to process your data for the establishment, exercise or defence of legal claims. You may always object to further use of your data for direct marketing purposes by contacting us.
You have the right to request rectification of your personal data if you believe our records are inaccurate or incomplete.
In some circumstances, you may request erasure of your personal data. We will comply with such a request if it is no longer necessary to store or process your personal data.
You can exercise any of your rights by contacting us via the email address: email@example.com
We will only keep your personal data for as long as is necessary. This means that we will retain your personal data for as long as we have an active contract or business relationship with you, and after this, we will only keep your data for as long as is necessary for the purposes which it is stored.
As outlined above, some of the personal data you provide to us will be used in order to enter into a contract with you and to comply with our legal obligations.
Should you not provide us with the data we require to offer our service or request that we erase the personal data we hold, it is likely that we will not be able to deliver our services to you.
If you feel that we have not been complying with our obligations on data protection law or you wish to assert one of your rights, please contact us without delay using the contact details provided at the bottom of this page.
Should you be dissatisfied with our response or wish to complain to the relevant supervisory authority, you can do so by contacting the Information Commissioner’s Office (ICO). Contact details for the ICO can be found on this webpage.