Date: August 2018
Privacy Statement Summary:
|Who will use my data?||Convex Capital Limited|
|What for?||We will store and process your data in order to allow us to provide our services to you. We will only process your data in relation to financial services with your explicit consent.
|What will happen if I contact you?||If you contact us we will use your information to send you the information you have requested.
|What data will be stored?||We will store your personal details in order to provide our services to you.
|What data will be shared?||We will not share your data with any third parties other than in relation to a transaction with parties that you have approved and only for the purpose of progressing a transaction.
|How long?||Your data will be stored only for 7 years after which time your data will be deleted.
|Who can access my data?||We will never sell, share or otherwise distribute your data to any other third party.|
|How is my data kept secure?||We will store your data on secure, encrypted US based servers. We may also store your data on our secure, encrypted dataroom servers based in Canada. We use industry standard security protocols/technology to secure data.
We take your privacy seriously and will only use your personal information to provide the products and services you have requested from us and to send you information about products and services you may be interested in. We will never sell, share or use your personal information other than as described here.
This policy sets out how we will use and share the information that you give us. This policy describes your relationship with Convex Capital Limited.
The Data Protection Act 1998 (DPA) and General Data Protection Regulation (GDPR) describes how organisations must collect, handle, process and store personal information.
These rules apply regardless of whether data is stored electronically, on paper or on other materials.
To comply with the law, personal information must be collected and used fairly, stored safely and not disclosed unlawfully. GDPR is underpinned by eight important principals. These say that personal data must:
- Be processed fairly and lawfully
- Be obtained only for specific, lawful purposes
- Be adequate, relevant and not excessive
- Be accurate and kept up to date
- Not be held for any longer than is necessary
- Processed in accordance with the rights of the data subjects
- Be protected in appropriate ways
- Not be transferred outside the European Economic Area, unless that country or territory also ensures an adequate level of protection.
- We take these responsibilities seriously, this document describes our approach to data protection.
This policy helps to protect us from data security risks, including:
- Breaches of confidentiality. For instance, information being given out inappropriately.
- Failing to offer choice. For instance, all individuals should be free to choose how the company uses data relating to them.
- Reputational damage. For instance, the company could suffer if hackers successfully gained access to sensitive data.
Who We Are And How To Contact Us
Convex Capital Limited is a limited company registered in England & Wales under number 11491052 and is registered with the Information Commissioner’s Office under the Data Protection Act 1998. The data controller is: Nathalie Hodgkinson. You can contact us in any of the following ways:
Phone:0161 819 2500
4 Castle Street
Convex Capital Limited is a corporate finance provider. This policy relates to users of Convex Capital Limited. Processing of your data is required in order to offer you these services. This policy applies to individuals who have shared their data with Convex Capital Limited as either a customer, employee, supplier or in any other capacity.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the DPA and GDPR. This can include:
- Names of Individuals
- Postal addresses
- Email Addresses
- Telephone numbers
- ….plus any other information relating to individuals
What this policy applies to
This section describes the lawful basis for processing your data and applies to the information about yourself that you choose to provide us with or that you allow us to collect. This includes:
- Information you contact us and request information such as your name, email address and contact details, and other preferences
- When you contact us in order to discuss using our services
- Information we collect about how you use the website
- Information relating to products and services we offer to you and other transactions including financial and other personal information required to complete these transactions
- Information given and stored as part of our ongoing relationship
- We do not collect or process sensitive data about you.
How your information will be used
We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing, for example:
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer||(a) Identity, (b) Contact||Performance of a contract with you|
|To process and deliver the services you including managing payments, fees and charges, and to collect and recover money owed to us||(a) Identity, (b) Contact, (c) Financial, (d) Transaction, (e) Marketing and Communications||(a) Performance of a contract with you, (b) Necessary for our legitimate interests to recover debts owed to us
|(a) Performance of a contract with you, (b) Necessary to comply with a legal obligation,
|To administer and protect our business and our site (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, to prevent fraud and in the context of a business reorganisation or group restructuring exercise, (b) Necessary to comply with a legal obligation|
|To improve our website, services, marketing, customer relationships and experiences||(a) Technical, (b) Usage||Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy|
We may collect and process information about you, including your name, date of birth, address, contact details (including email address and mobile phone number), product and service details, purchase history and data collected as part of any finance application or payment (including previous addresses, employment details and bank account details). We may take personal information from:
- Information that you provide to us when registering with our website (including your email address);
- Information that you provide when completing your online profile (including your name, gender, date of birth and any educational details and employment details you provide);
- Information that you provide to us when signing up to any distribution lists to receive correspondence from us;
- Information relating to any purchases you make of our goods or services, including any other transaction details made via any of our websites (including your address, telephone number and payment details)
Personal data we receive will be used for the purposes it was provided, including:
- To respond to queries from you regarding the provision of services;
- To carry out our obligations arising from any contracts entered into between you and us including provision of services, and to respond to queries from you regarding those contracts;
- To manage and administer the relationships between you and us;
- To notify you about changes to our services and to otherwise communicate with you; for example, we will use your contact details in order to respond to any queries that you submit to us; and
- To obtain feedback from you regarding us
In accordance with your preferences, we may also use your personal information to provide you with information about services that may be of interest to you. We may use your personal information in order to ascertain the services that are likely to be of particular interest to you. This document explains how you can change whether to receive this information. Please note that, even if you choose not to receive this information, we may still use your personal information to provide you with important services communications, including communications in relation to any purchases you make or services you use.
How to change your preferences
We operate in line with EU GDPR (May 2018) data protection guidelines. We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing. We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller or you can visit our website, call, or email us to contact us to change your preferences at any time.
Scope of Agreement
We may from time to time use your information for marketing, account management or relationship management purposes. The main purpose of this is to provide you with information about goods and services which we think may be of interest to you and/or to maintain any existing relationship we may have with you.
Opting out at a later date
Where you give your consent for us to process your data, or where you agree to us processing financial data, you can contact us to amend or withdraw your consent at any time. You can also choose to object to processing and request deletion of your data. We respect all user rights as defined in GDPR. If you have any comments or wish to complain please contact us.
How we store and process your data
Your data will be collected and processed in the UK only and stored in the US on secure encrypted servers. Your data will be stored for up to 7 years to ensure we have records of service, payments, and other interactions we have with you.
In order to provide services to you we use recognised third parties to take payment, conduct credit reports and other checks, manage our company accounts and provide banking services. We will store transactions, payment and order data for up to 7 years or for as long as required by UK financial and company regulations. These third parties may operate outside the EU, if this is the case we will ensure precautions are in place to protect your data.
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information].
You will only receive marketing communications from us if you have:
- Requested information from us or purchased goods or services from us; or
- If you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
- In each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
We are a data controller. In relation to the information that you provide to us, we are legally responsible for how that information is handled. We will comply with the Data Protection Act 1998 and the GDPR (2018) in the way we use and share your personal data. Among other things, this means that we will only use your personal data:
- Fairly and lawfully
- As set out in the legislation and this policy
- To the extent necessary for these purposes
- We will take steps to ensure your data is accurate and rectify data as necessary
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
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 may refuse to comply with your request in these circumstances.
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. 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 a number of requests. In this case, we will notify you and keep you updated.
We may have to share your personal data with the parties set out below for the purposes described in this document:
- Service providers who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, credit scoring, banking, legal, fraud protection, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
- Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
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 such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.
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 notice of every website you visit.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Under the Data Protection Act, we are also permitted to share some information with third parties who use such data for non-marketing purposes (including credit and risk assessment and management, identification and fraud prevention, debt collection and returning assets to you).
Contacting us, exercising your information rights and Complaints
If you remain dissatisfied then you have the right to apply directly to the Information Commissioner for a decision. The Information Commissioner can be contacted at:
Information Commissioner’s Office