Data protection privacy notice
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.
What is personal information?
Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.
Who we are
Alcuin Capital Partners LLP is the Controller 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 Adrian Lurie, our Compliance Officer, using the details set out below:
Postal address: 65 Sloane Street, London, SW1X 9SH
Contact telephone number: +44 203 178 4089
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), 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.
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 do we collect information about you?
Typically we will collect information from you when you contact us directly or provide information in order for us to provide our products and services. We collect information from and about you in the following ways:
Through direct interactions when you give us your personal information by filling in forms or during correspondence with us. This includes when you:
Apply for our products and services;
Email us or provides us with a business card;
Meet with us in person or speak on the phone;
Reply to CDD requests; and
Enter into a contract with us (eg invest in a fund).
Apart from the information we collect directly from you we may collect the following information from third parties in the course of seeking out for potential investors and/or research clients.
When seeking out for potential investors for the fund(s) we manage we may collect the following from a mutual contact or introducer:
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.
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 have agreed to provide financial advice or to manage investments for you and have a contractual agreement to do this.
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 prevent fraud.
We set out in the table below all the ways we plan to use your personal information and the legal bases we rely on to do so. We also explain what our legitimate interests are where appropriate:
|Purpose||Lawful basis for processing including our legitimate interests|
|To on-board you as a new investor||To fulfil our contact with you
To fulfil our legal obligations to prevent financial crime
|To manage your account||Necessary for our legitimate interests – to recover debts due to us|
|To monitor your investment on an on-going basis||To fulfil our contract with you|
|To meet our regulatory obligations to provide you with regular information about your investment||To fulfil our regulatory obligations|
|To contact you about other products and services we think you may be interested in||Necessary for our legitimate interests – to develop our products and services and grow our business|
|To purchase services from our suppliers||To fulfil our contracts with suppliers|
|To use data to improve our website||Necessary for our legitimate interests – to understand how our customers interact with our website|
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.
We want to contact you about products or services we feel will be of interest to you or of benefit. We use your personal information to communicate with you if we have either your consent or a ‘legitimate interest’. We believe that as a commercial enterprise we do have a legitimate interest in contacting you about our products or services and we will only do so if we decide it would be of interest or beneficial for you.
You are free to change your mind at any time by contacting the Compliance Officer.
Who we share your information with
For investors in our fund(s) 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 the purpose of 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 fund(s) you are invested in;
The fund’s bank; and
The fund’s administrator; and
The fund’s tax advisors.
Sending your information outside of the EEA
The regulations which have been put in place to protect your privacy apply throughout the EEA. The EEA is the European Economic Area which includes all the countries in the European Union plus Iceland, Liechtenstein and Norway. This means that any country within the EEA must meet the same privacy standards as the United Kingdom. All the personal information that we hold about you will be processed in the United Kingdom.
Storing your information
The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. When we decide how long we will retain your personal information, we will take into account the amount, nature, sensitivity of your information and how we want to use it as well as the potential risk of harm being caused from unauthorised use or disclosure. We review our retention periods for personal information on a regular basis and will ensure all records are safely destroyed if we no longer need to retain them or you have contacted us to request so.
You are provided with a number of 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; and
To withdraw your consent.
If you wish to exercise any of these rights please contact the Compliance Officer. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.
We have put in place appropriate security measures to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have a procedure to deal with any suspected personal data breach and will notify you, and other regulators, where we are legally required to do so.