We are committed to protecting your personal information and ensuring we respect your privacy. This Privacy Notice explains how we will look after and use any personal information that we collect about you.
Our website is not intended for children and we do not knowingly collect data relating to children from our website. If the products or services we supply to you require us to collect data relating to children, relevant information will be provided to you in an appropriate notice.
It is important that you read this privacy notice together with any other privacy notice that we may provide on specific occasions when we are collecting or processing your personal data.
WHO WE ARE
Europa Capital Limited Liability Partnership and Europa Capital Partners LLP are the Controllers of the personal information you provide to us. If you have any questions about this Privacy Notice or the information we hold about you please contact us using the details set out below:
Full name of legal entity: Europa Capital Limited Liability Partnership
Email address: firstname.lastname@example.org
Postal address: 42 Berners Street, London, W1T 3ND
Contact telephone number: +44 207 881 6800
Europa Capital Partners LLP is registered with the Information Commissioners Office under registration number Z2263787.
You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
WHAT TYPES OF INFORMATION DO WE USE?
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We collect information while providing our financial services to you. The information which we may collect, use, store and transfer about you include:
- Your personal details, such as your;
- Date of birth;
- Marital status;
- Country of residence;
- Tax or social security identifiers;
- Your banking details;
- Your profession, qualifications and employment history; and
- Your home and professional address, including email addresses, postal addresses and/or telephone numbers.
- Identification documentation, such as copies of your passport, driving licence, ID card or other documentation required by local law. Copies of these documents may include a photograph of your face and shoulders.
- Information provided through our recruitment process.
- Details of your visits to our premises.
- Details of people with whom you are connected, including your family, colleagues and others;
- Information regarding entities with which you are connected, including:
- your employer;
- your advisors;
- banking and other service providers; and
- entities in which you have an interest.
- Your marketing and other preferences; and
- Information which you provide to us while corresponding with us.
We do not collect any special categories of personal data. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data.
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
CONSEQUENCES OF NOT PROVIDING SOME TYPES OF INFORMATION
Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the goods or services you asked for. In this case we may have to cancel the product or services but we will tell you if this is the case.
HOW WE WILL USE YOUR PERSONAL INFORMATION
We only obtain, use and keep personal information where we need it for a specific purpose. We set out in the table below the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason or basis for doing so. This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected. Most commonly we will use your information in the following ways:
- We have a contract with you. For example, we manage a fund for which you are an investor or an investor’s representative, employee or agent in accordance with the constitutional documents of the fund.
- We have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example, this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
- We, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interests. For example, processing your information to source real estate investment opportunities.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing email@example.com and using the subject line “GDPR request”
We set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
We will only use your personal information for the reason for which we collected it. We will only use it for another reason if we believe that new reason is compatible with the original purpose. If we do need to use your personal information for a non-related purpose we will tell you about it and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
WHO WE SHARE YOUR INFORMATION WITH
We may need to provide information to third parties for a variety of reasons, for example, we may need to provide information to assist in the detection or prevention of crime or for safeguarding national security. Please refer to the table in the section ‘How we will use your personal information’ which explains how we use your data. The third parties we share your information with are as follows:
- The funds you are invested in
- Our service providers such as IT administrators, accountants, fund administrators, bankers and lawyers
- Counterparties to a transaction
- HM Revenue & Customs, regulators and other relevant authorities
- Other members of our group, which includes our subsidiaries and members together with their respective affiliates, including subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
SENDING YOUR INFORMATION OUTSIDE OF THE EEA
The regulations which have been put in place to protect your privacy apply throughout the EEA. As explained in the section above we may send your information to other third parties who are based outside of the EEA, however we will only share your information with them because the country we send your information to is deemed to provide an adequate level of protection by the European Commission.
You can obtain further information on the specific mechanism used by us when transferring your personal information outside of the EEA by emailing firstname.lastname@example.org and using the subject line “GDPR request”.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
STORING YOUR INFORMATION
As a financial services provider, we will typically have a contract with you and will need to keep your personal information (updated to ensure accuracy) to fulfil our contract. We also need to comply with EU and UK law, which often requires us to keep certain records – which will include certain personal information – for several years.
Our policy is to keep records on prospective investors and other business contacts indefinitely as we may wish to contact long standing contacts about a particularly relevant opportunity in the future, and in the context of real estate business there is no way to predict when such an opportunity might arise. We will ensure all records are safely destroyed if we no longer need to retain them. We review our retention periods for personal information on a regular basis. We will tell you if we change the retention period.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
You are provided with several different rights under the data protection laws in relation to your personal information. These allow you:
- To access your information;
- To request we correct your information;
- To request that we erase your information;
- To object to the processing of your information;
- To request a restriction in the processing of your information;
- To request a transfer of your information;
- Complain to the Information Commissioner’s Office; and
- To withdraw your consent.
If you wish to exercise any of these rights please contact email@example.com and use the subject line “GDPR request”. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request in these circumstances.
To confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights) we may need to request specific information from you. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.