Privacy Policy
PLEASE READ THESE TERMS CAREFULLY BEFORE USING THIS SITE
Last updated on 7 July 2021
Introduction
This privacy policy applies between you, the user of this website, (you or your) and Napatree Capital Advisers Limited, a private company registered in England with company registration number 12963860 (we or our).
We respect your privacy and are committed to protecting your personal data in accordance with all applicable law, including the UK GDPR, the Data Protection Act 2018, the EU GDPR, and the Privacy and Electronic Communications (EC Directive) Regulations 2003. This privacy policy will inform you how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights.
Important information
1. This privacy policy aims to give you information on how we collect and process your personal data through your use of this website.
2. This website is not intended for children and we do not knowingly collect data relating to children.
3. It is important that you read this privacy policy so that you are fully aware of how and why we are using your data.
4. We are the controller and responsible for your personal data.
5. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our information rights officer using the details set out below:
Name: Penny Bodle
Address: 4 Coleman Street, 6th Floor, London, EC2R 5AR
E-mail: contact@napatreecapitaladvisors.com
6. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy policy and your duty to inform us of changes
7. We keep our privacy policy under regular review. This version was last updated on the date set out above.
8. 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.
Third-party links
9. This 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 policy of every website you visit.
The data we collect about you
10. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous or anonymised data).
11. We do not currently enable website users to create an account with or provide information via our website. As a result we do not currently collect any data on users of our website.
12. However, in the event that this functionality is added in the future we may collect, use and store different kinds of personal data about you which we have grouped together as follows:
· Identity Data includes first name, last name, title, age and gender.
· Contact Data includes address, email address and telephone numbers.
· Profile Data includes your username and password that will be used to create an account with our online shop and your responses to surveys about new social groups.
We may also collect some of this data is you separately provide it to us through your business communications with us. We do not share this data with third parties.
13. We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users interested in a specific website feature. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, then we will treat the combined data as personal data which will be used in accordance with this privacy policy.
14. We do not collect any Special Categories of Personal Data about you (this includes for example details about your race or ethnicity, religious or philosophical beliefs, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
How is your personal data collected?
15. We only collect data from and about you that you directly provide to us. For example, you may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
· discuss or engage in a business relationship with us; or
· give us feedback or contact us.
16. We do not use cookies to track you interactions with our website and we do not use other automated mechanisms for gathering your personal data.
How we use your personal data
17. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where the processing of your personal data is necessary to comply with a legal obligation to which we are subject.
Marketing & Third Parties
18. We do not share your data with third parties. If we were to propose sharing your data with third parties, we would first get your express opt-in consent.
19. We may from time to time contact you by e-mail with news and information about us and our activities. If you do not wish to receive these updates please contact us at any time, or choose the unsubscribe option in the relevant e-mail.
Change of purpose
20. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you want us to explain how the processing for the new purpose is compatible with the original purpose, please contact us.
21. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
22. 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.
International transfers
23. We do not transfer your personal data outside the UK.
Data security
24. 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.
25. 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.
Data retention
26. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
27. Unless required by law or as set out above, we will generally delete your personal data 12 months after your last interaction with us.
28. In some circumstances you can ask us to delete your data: see the Your Legal Rights section below for further information.
29. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your legal rights
30. You have rights under data protection laws in relation to your personal data. These rights re set our below. If you wish to exercise any of these rights set out above please contact us.
31. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
32. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. To speed up our response we may also contact you to ask you for further information in relation to your request.
33 We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
34 You have the following rights:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Governing law
35. This privacy policy, its subject matter and its formation (and any non-contractual disputes or claims) are governed by English law.
36. By using our site you agree to the exclusive jurisdiction of the courts of England and Wales to settle any disputes relating to this privacy policy or our site.