Clyde Blowers Capital IM LLP, a Scottish Limited Liability Partnership (Company Number SO301657) and having our registered office and principal place of business at Orbital House, 3 Redwood Crescent, East Kilbride G74 5PA (“CBC” or “we”, “our” or “us”) is committed to protecting the security and privacy of all personal information or data collected from you. We therefore conduct our business in compliance with applicable laws on data privacy protection and data security. This privacy statement tells you what to expect when we collect and process your personal information.
We try to meet the highest standards when processing your personal information. The data controller who is responsible for how we handle your personal information is Clyde Blowers Capital IM LLP. Any queries you have in relation to the same should be directed to firstname.lastname@example.org.
We may ask you to provide certain information about yourself when you use our website or are in contact with us about the activities we are engaged in (whether it is by telephone, email, via the forms on our website or even face to face).
There are four distinct groups we have dealings with. These are:
(1) business contacts;
(2) investors or potential investors;
(3) actual or potential management teams; and
(4) suppliers and professional advisers.
In respect of business contacts this includes individuals who email us or whom we may have met at presentations or events or who have been introduced to us by other parties. It also includes individuals who may choose to subscribe to our newsletter or who browse our website. Personal information collected about this group may include:
Our legal basis for doing so under the General Data Protection Regulation EU 2016/679 (“GDPR”) is that such processing is in our legitimate interests in respect of running our business andensuring security and performance of our website.
In respect of investors or potential investors personal information collected may include:
The personal information we hold about investors or potential investors will be held solely for the following purposes:
Our legal basis for doing so under GDPR is either performance of a contract with you, legal obligation or that such processing is in our legitimate interests in respect of running our business andensuring security and performance of our website.
In respect of actual or potential management teams personal information collected may include:
The personal information we hold about actual or potential management teams will be held solely for the following purposes:
Our legal basis for doing so under GDPR is either performance of a contract with you, legal obligation or that such processing is in our legitimate interests in respect of running our business in particular by considering potential investments and administering transactions that we enter into. Legitimate interests also includes ensuring security and performance of our website.
In respect of suppliers and professional advisers personal information collected may include:
The personal information we hold about suppliers and professional advisers will be held solely for the following purposes:
Our legal basis for doing so under GDPR is either performance of a contract with you, legal obligation or that such processing is in our legitimate interests in respect of running our business.
Given the nature of our activities, it is extremely unlikely that we will require to collect any sensitive data about any individuals within any of the groups we have dealings with (other than details of your nationality in the case of investors or potential investors or actual or potential management teams). Sensitive data is personal information which includes your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic or biometric data, or information concerning your health or mental wellbeing or sexual orientation. Where we do require to process such sensitive data to in respect of you, we will notify you in advance and will request your express consent in writing to process such sensitive data unless there are some other legitimate grounds which allow us to process such data.
If you do not wish us to collect any of the personal information stated above, you should discuss this with us. We can explain the reasons for collection and discuss the consequences of not providing the information or of providing partial or incomplete information and the effect this may have on our ability to perform our activities.
We will not sell the personal information that we collect from you and will only use it for the purposes set out in this privacy statement. We may share your personal information with the following parties:
All third parties with whom we share your data are required to protect your personal data, treat it confidentially and to process it in accordance with the law. Where we use third parties we will take all reasonable steps to ensure that they are GDPR compliant and in particular that:
We will only retain your personal information for as long as is necessary in line with the purposes for which it was originally requested or collected or where we are required to do so for some legal or reporting purpose.
In working out how long we retain personal data we look at the type of personal data involved, the purpose of processing, how sensitive or confidential the data is and at legal and commercial considerations including any legal obligations we have. By way of example by law we are required to keep accounting records for six years after end of the year in which the last transaction occurred. This means that we will be required to keep some basic details for that purpose even although our relationship with you may be at an end. However, it should be noted that the requirement is basic details and therefore it is not legitimate also to keep information such as your preferences for that period of time.
If you have any questions relating to either retention periods or require more detail on the purposes of processing or the specific reason or legal grounds we are relying on for that processing, then please contact us for additional information.
We may provide you with information on our activities. This is regarded as marketing activity. We will only market to you where you have:
If you have opted out of marketing, we will not send you any future marketing without your consent.
Each time we market to you we will always give you the right to opt out of any future marketing but would point out that you have the right at any timeto ask us not to market to you at any time by emailing us at email@example.com rather than waiting on a specific opt out.
We may use analytics to understand how you interact with content in our e-marketing.
We take information security very seriously. Your information and records will be stored securely to ensure privacy of your personal data. We take all reasonable steps to ensure that there are technical and organisational measures of security in place to protect your personal data from unauthorised access to or disclosure of it, and against loss or accidental damage or unauthorised alteration of it. Staff handling your personal data are also adequately trained in relation to the legal requirements for handling personal data. These include robust procedures for dealing with breaches including incident reporting and notifying the Information Commissioner, and where appropriate you, of any breaches, the consequences of the same and the remedial action taken.
Where possible the information you provide us with will be held within the European Economic Area (“EEA”) or within the UK.
Countries outside of the EEA do not always have similar levels of protection for personal data as those inside the EEA. The law provides that transfers of personal data outside of the EEA is only permitted where that country has adequate safeguards in place for the protection of personal data. Some types of processing may use cloud solutions which can mean information may sometimes be held on servers which are located outside of the EEA or may use processors who are based overseas.
Where we use cloud-based services or third-party providers of such services and in either or both circumstances the data is processed outside of the EEA that will be regarded as an overseas transfer. Before instigating an overseas transfer, we will ensure that the recipient country and/or processor has security standards at least equivalent to our own and in particular one of the following permitted safeguards applies:
If none of these safeguards exist, then we may seek your explicit consent for an overseas transfer. In line with your rights as an individual you are free to withdraw this consent at any time.
You have rights as an individual which you can exercise in relation to the information we hold about you. These rights are:
Additional information about these rights can be found on the Information Commissioner’s website at www.ico.org.uk/for-organisation/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you have provided consent and we are relying on that as the legal ground of processing your personal information and wish to exercise your right to withdraw that consent you can do so at any time by contacting us at firstname.lastname@example.org.
We try to be as open as we can in giving people access to their personal information. You can make a subject access request at any time about the personal information we process about you. Any request requires to be in writing and is not subject to any charges or fees. If we do hold any personal information about you, we will:
We will respond to a subject access request within 30 days. On occasion we may need additional information from you to determine your identity or help us find the information more quickly. Where the information you have requested is complex we may take longer than this but shall keep you advised as to progress should this be the case.
If you believe that any information we hold about you is incorrect or incomplete you should email us at email@example.com . Any information which is found to be incorrect will be corrected as soon as possible.
We would prefer to resolve any issues or concerns you may have direct with you. If you feel you are unable to resolve matters by contacting us direct or are you are unhappy or dissatisfied with how we collect or process your personal information you have the right to complain about it to the Information Commissioner who is the statutory body which overseas data protection law. They can be contacted through www.ico.org.uk/concerns.
Questions, comments and requests regarding this privacy statement are welcomed and should be addressed to firstname.lastname@example.org.
We keep our privacy notice under regular review. This privacy notice was last updated on 25th May 2018.