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Website Privacy Policy

WEBSITE PRIVACY POLICY – October 2019

INTRODUCTION

East Lodge Capital Partners LLP (“East Lodge Capital”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to 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 and how the law protects you.

1.  IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how East Lodge Capital collects and processes your personal data through your use of this website, including any data you may provide through this website when you register.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

East Lodge Capital is the controller and responsible for your personal data (collectively referred to as the “Firm”, “we”, “us” or “our” in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

CONTACT DETAILS

Our full details are:

East Lodge Capital Partners LLP, Aldermary House, 10-15 Queen Street, London EC4N 1TX

Data Privacy Manager:  Ken Towers

ken.towers@eastlodgecapital.com

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 (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.

YOUR DUTY TO INFORM US OF CHANGES

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.

2. THE DATA WE COLLECT ABOUT YOU

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 data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, title.
  • Contact Data includes email address and telephone number.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data includes information about how you use our website
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect and use 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.

We do not collect any Special Categories of Personal Data about you (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 and biometric data). Nor do we collect any information about criminal convictions and offenses.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you
    •  Register for full access on our website; or
    •  Request investment communications be sent to you.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

4. HOW WE USE YOUR PERSONAL DATA

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.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending investment communications to you via email. You have the right to withdraw consent to these communications at any time.  Please contact us if you would like to do so.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of all 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.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you when you visit our website

 

(a) Identity

(b) Contact

 Necessary for legitimate interest (to comply with your request)

To manage our relationship with you which will include notifying you about changes to our terms or privacy policy

 

(a) Identity

(b) Contact

 

(a) Necessary to comply with a legal obligation

(b) Necessary for our legitimate interests (to send investor communications to you)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security or to prevent fraud)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website

 

(a) Technical

(b) Usage

 

 Necessary for our legitimate interests (to keep our website updated and relevant) 


INVESTMENT INFORMATION FROM US

You will receive investment communications from us if you have requested information from us and you have not opted out of receiving those communications.

OPTING OUT

You can ask us to stop sending you investment communications at any time by following the opt-out links on any investment communication sent to you or if you contact us at any time.

Where you opt-out of receiving these communications, this will not apply to personal data provided to us as a result of registering to use the website.

COOKIES

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

CHANGE OF PURPOSE   

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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with service providers acting as processors who provide IT and system administration services for the purposes set out in the table in paragraph 4 above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area.

7. DATA SECURITY

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 members of staff 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.

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

  • the right to request access to your personal information;
  • the right to have your personal information rectified;
  • the right to have your personal information erased;
  • the right to request that your personal information is only used for restricted purposes;
  • (if the lawful basis for processing your personal information is the legitimate interest of the Fund/ the Investment Manager) the right to object to your personal information being processed, for example, for marketing;
  • (in some circumstances) the right to require certain of your personal information to be transferred to you or a third party; and
  • the right to lodge a complaint with the relevant data regulator in your jurisdiction.

If you wish to exercise any of the rights set out above, please contact the Data Privacy Manager.

10.  GLOSSARY

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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).

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.