Included in this privacy notice are your data protection rights and obligations as described by the Data Protection Act (DPA) and the General Data Protection Regulation (GDPR), together referred to as “Regulations”.
We place great importance on your privacy, we recognise the need to protect personal data and are committed to collecting and using such data fairly and in accordance with the requirements of Regulations.
How we gather and use personal data
- We obtain information about you so that we can provide you with our Capital Introduction services, and in some cases to meet our legal, statutory and contractual obligations.
- This information is sometimes obtained through analysing online and offline public information.
- We may also receive information from third party sources e.g. by way of due diligence or to carry out or assist anti-money laundering (“AML”).
- We also obtain personal data from notes made on calls or meetings.
- We will retain your personal data as long as necessary to maintain our business relationship, or as long as may be required for other purposes such as regulatory or legal obligations.
What personal data we collect
- We collect personal data to provide Capital Introduction services. The type of personal data we collect may include your name, phone number, email, company name, company address. This is necessary for the provision of our services both to investor clients and fund manager clients. We also collect notes on past encounters and communications with you, your organisation or someone within your organisation.
- We may sometimes be required by laws and regulations to collect and process special categories of data under the Regulations.
- We do not collect data through our website.
How we use your personal data
- We will never disclose, share or sell your data without your consent or unless required to do so by law or regulation.
- We collect information about you in order to provide you with our Capital Introduction services. You are free to opt out at any point by emailing us at email@example.com.
Why we process personal data
- We process your information when contractual obligations require us to do so.
- We process your data for marketing, promotional and newsletter emails.
- We may process data when the data subject has given consent to the processing of his/her data for a specific purpose – e.g. sending marketing information; sharing the data with another party.
- We process your data for legitimate interests pursued by Westhall Partners or a third-party (except when such interests are superseded by your interests or your fundamental rights and freedoms as outlined by the Regulations).
How we protect your personal data
- We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, or unauthorised alteration or destruction.
Sharing your personal data
- With your consent (including but not limited to verbal or email), we may disclose your personal data to third parties including Fund Managers, Investors and their associates as part of our Capital Introduction service.
- We do not share or disclose any of your personal information without your consent, other than when required by law or to carry out legitimate interests (e.g. using third party services for due diligence).
- The disclosure of personal data to the affiliates and other third parties set out above may involve the transfer of data to jurisdictions outside the European Economic Area (‘EEA’). Such countries may not have the same data protection laws as the EEA.
Your data protection rights as outlined by the Regulations
For your convenience we have summarised your rights under the Regulations below.
- Right to withdraw consent: Where you have given us consent to use personal information, you can withdraw your consent at any time.
- Access your personal information: You can request access to a copy of your personal information.
- Portability: You can ask us to provide you or a third party with some or all of the personal data we hold about you.
- Rectification: You can ask us to change, complete or remove any inaccurate personal data we have about you.
- Erasure: You can ask us to delete your personal data where it is no longer necessary for us to use it, you have withdrawn consent, or where we have no lawful basis for keeping it.
- Right to object: You can object to our processing of your information.
- Restriction: You can ask us to restrict the personal data we use about you where you have asked it erased or where you have objected our use of it.
- Lodge a complaint: Should you be unhappy with how your personal data is processed, you may complain to the supervisory authority for data protection (in the UK it is the Information Commissioner’s Office).