Privacy Notice
Date: with effect from 25th May 2018

Belgrave Capital Management Ltd., registered in England No. 3105821, with its registered office at St James House, 13 Kensington Square, London W8 5HD. (“BCM”, “we”, “us” and “our”) is committed to respecting your privacy.


About this Privacy Notice

For the purposes of data protection law, we are a data controller in respect of your personal data. BCM is responsible for ensuring that it uses your personal data in compliance with data protection law.

This privacy notice applies if you are a customer or client; supplier; professional advisers and consultants; a visitor to our website or an employee; or a director, officer or representative of another organisation with which we have a business relationship.

This privacy notice sets out the basis on which any personal data about you that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.


Personal data that we collect about you

We will collect and process the following personal data about you:

  • Information that you provide to us or one of our affiliates. This includes information about you that you give us by filling in forms, registering on our website, completing surveys we use for research purposes or by communicating with us, whether face-to-face, by phone, e-mail or otherwise. This information may include (by way of a non-exhaustive list):
    • basic personal data such as first name; family name; email address; phone number; address (including city postcode and country); occupation and job title;
  • Information we collect or generate about you. This includes (by way of a non-exhaustive list):
    • information about your browsing actions and patterns on our website which may be collected through the use of “cookies”, “IP addresses” or other numeric codes used to identify your computer
    • files that we may produce as a record of our relationship with you, including contact history; and
    • any personal data that you provide during telephone and email communications with us which we may monitor and record in order to resolve complaints, improve our service and in order to comply with our legal and regulatory requirements.
  • Information we obtain from other sources. This includes (by way of a non-exhaustive list):
    • information from publicly available sources (including third party agencies such as credit reference agencies; fraud prevention agencies; law enforcement agencies; public databases, registers and records such as Companies House and the FCA Register; and other publicly accessible sources);
    • information obtained from professional advisers, product providers, events organisers, and other agents and/or representatives; and
    • information obtained from sanctions checking and background screening providers

Uses of your personal data

Your personal data may be stored and processed by using the following ways and for the following purposes:

  • for ongoing review and improvement of the information provided on our website, the services that we provide through it and the way that content is presented;
  • to determine your suitability to be granted access to the secure section of our website when you register to access it;
  • for research purposes and to identify opportunities and BCM events that may be of interest to you;
  • to allow for use and access to our products and services and to keep our records up to date;
  • to monitor IT systems in order to protect against cyber threats or malicious activity including abuse and misuse;
  • to administer or maintain IT systems in order to uphold standards of service;
  • to understand feedback on our products and services and to help provide more information on the use of those products and services quickly and easily;
  • to communicate with you in order to provide services or information about other BCM products and services;
  • for the management and administration of our business;
  • in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
  • for the administration and maintenance of databases storing your personal data.

When we use your personal data, we make sure that such usage complies with applicable law. The law allows or requires us to use your personal data for a variety of reasons. These include instances where:

  • we are performing our contractual obligations;
  • we have legal and regulatory obligations that we have to discharge;
  • we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
  • the use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates), such as:
    • allowing us effectively and efficiently to manage and administer the operation of our business;
    • maintaining compliance with internal policies and procedures;
    • enabling quick and easy access to information on BCM’s products and services.

Disclosure of your information to third parties

We may disclose your personal data to our affiliates for the purposes described above. We will take steps to ensure that the personal data is accessed only by employees of such affiliates that have a need to do so for the purposes described in this notice.

We may also share your personal data outside of BCM and our affiliates:

  • with our business partners who are contractually obliged to comply with appropriate data protection obligations
  • if we sell any of our business or assets, in which case we may disclose your personal data to the prospective buyer for due diligence purposes;
  • if we are acquired by a third party, in which case personal data held by us about you will be disclosed to the third party buyer;
  • to third party agents or contractors (for example, administrators, BCM’s auditors, professional advisors, IT and communications providers, background screening providers, and credit reference agencies) for the purposes of providing services to us. These third parties will be subject to confidentiality requirements and appropriate data protection obligations; and
  • to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, establish, exercise or defend our legal rights.

Transfers of personal data outside the European Economic Area

The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for our affiliates or for one of our suppliers.

Where we transfer your personal data outside the EEA, we will ensure that it is protected in a manner that is consistent with how your personal data will be protected by us in the EEA. This can be done in a number of ways, for instance:

  • the country that we send the data to might be approved by the European Commission;
  • the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data; or
  • where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.

In other circumstances the law may permit us to otherwise transfer your personal data outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.

You can obtain more details of the protection given to your personal data when it is transferred outside the EEA under a written contract (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Contacting us” section below.


Retention of personal data

How long we hold your personal data for will vary. The retention period will be determined by various criteria including:

  • the purpose for which we are using it – we will need to keep the data for as long as is necessary for that purpose; and
  • legal obligations – laws or regulation may set a minimum period for which we have to keep your personal data.

Your rights

You have a number of legal rights in relation to the personal data that we hold about you. These rights include:

  • the right to obtain information regarding the processing of your personal data and access to the personal data which we hold about you;
  • the right to withdraw your consent to our processing of your personal data at any time. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so;
  • in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
  • the right to request that we rectify your personal data if it is inaccurate or incomplete;
  • the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we are legally entitled to retain it;
  • the right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal data but we are legally entitled to continue processing your personal data and / or to refuse that request; and
  • the right to lodge a complaint with the data protection regulator (details of which are provided below) if you think that any of your rights have been infringed by us.

You can exercise your rights by contacting us using the details set out in the “Contacting us” section below.

You can find out more information about your rights by contacting the UK Information Commissioner’s Office, or by searching their website at https://ico.org.uk/.


Cookies

A cookie is a small file that is sent to your browser from a web server and is stored on your computer. Cookies help us to analyse web traffic and identify which pages of our Website are being used. Our Website also uses cookies to respond to you as an individual so that it can tailor its operations to your needs by gathering and remembering information about your preferences as well as enabling you to login to and use the section entitled “Fund Information”. We only use this information for statistical analysis purposes and then it is removed from our systems.

A cookie in no way gives us access to your computer or any information about you, other than information about how you use the Website and the Personal Information you choose to share with us (including Personal Information you automatically share with us by way of your browser settings).

In particular, we use the following cookies:

  • Essential cookies. These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas.
  • Performance cookies. These cookies collect information about how visitors use our Website, for instance which pages visitors go to most often and if they get error messages from the web pages. These cookies don't collect information that identifies a visitor; all information these cookies collect is aggregated and therefore anonymous. It is only used to improve how our Website works.

You can also manage cookie use via your browser settings (this will allow you to refuse the setting of all or some cookies) and your browser provider may ask you to confirm your settings. Note, however, that if you block all cookies (including essential cookies) via your browser settings you may not be able to access all or parts of our Website.

You can also find more information about cookies generally here: www.allaboutcookies.org


CHANGES TO THIS PRIVACY POLICY

BCM may amend this Policy at any time without notice. By continuing to use the Website and making use of our services you acknowledge that we shall process your Personal Information in accordance with the updated Policy. If you are not happy with any changes that we make, you should not use or access (or continue to use or access) the Website and/or our services. Any changes to this Policy will be posted on the Website.

Contacting us

If you would like further information on the collection, use, disclosure, transfer or processing of your personal data or the exercise of any of the rights listed above, please address questions, comments and requests to [email protected].