PRIVACY NOTICE
This Privacy Notice is provided by Cadwyn Capital Management LLP (together “we” or “us” or Cadwyn Capital) and sets out our policies with respect to the collection, sharing, and use of personal information. We are committed to respecting your privacy.
About this privacy notice
For the purposes of data protection law, we are a data controller or data processor, as applicable, in respect of your personal data. Cadwyn Capital is responsible for ensuring that it uses any personal data provided by you in compliance with data protection law.
This privacy notice applies if you are an existing client, a prospective client, or job applicant. This privacy notice sets out the basis on which any personal data that you provide to us, that we create, or that we obtain about you from other sources, will be processed by us. Please take the time to read and understand this privacy notice.
Definition of personal data
For the purpose of this privacy notice, “personal data” refers to any information related to a natural person which, on its own or in combination with any other information, can be used to identify a person.
Personal data we may collect and process about you
The categories of personal data we may collect will depend on the nature of our relationship with you and the purpose for which information is being collected. Such personal data may include names, residential addresses or other contact details, signature, nationality, date and place of birth, national insurance or other tax identification number, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, criminal and administrative offenses, source of funds details, or other sensitive information, such as certain special categories of personal data contained in relevant documents or materials (possibly including, in some circumstances, information about a person’s ethnic origin, religious beliefs, or health).
How we collect information about you
We may collect and process personal data about you through:
information provided directly to us by you, or another person on your behalf, through our website, by email or post, or in person;
information that we obtain in relation to any transactions between you and us;
recording and monitoring of telephone conversations and electronic communications with you;
in some circumstances, we may receive personal information about you from third parties, such as service providers or trading counterparties, regulatory or law enforcement agencies, credit reference agencies and agencies conducting background checks. Personal information may also be obtained from publicly accessible sources of information, such as public databases, industry associations, social media and online professional networks.
We do not use automated data processing decision making processes.
Uses of your personal data
We may collect and use your personal information for the purposes of administering the relationship between us, marketing our products and services to you or the businesses with which you are associated, monitoring and analysing our activities, and complying with applicable legal or regulatory requirements.
We will use one of the permitted grounds under the applicable law to process your information. Such grounds include instances where you have given your consent and cases where your consent is not required under applicable law, such as where we are required to comply with a legal obligation, or where we, or a third party, determine that it is necessary for our legitimate interests to collect and use your personal information.
The legitimate interests to collect your personal information may include any of the purposes identified above and any other purpose where we or a third party have determined that you have a reasonable expectation for us or a third party to collect or use your personal information for such purpose. You have the right to object to the use of your personal data for direct marketing purposes.
Sharing of your information with third parties
We may share your personal data with third parties to the extent this is relevant or required including:
With the board of the funds we act as investment manager for, any regulators applicable to our business or to the funds, the administrator and/or custodian of the relevant fund, and any third parties you ask us to communicate with;
With third party agents or contractors (for example, the providers of our electronic data storage services) for the purpose of providing services to us. These third parties will be subject to confidentiality requirements and they will only use your personal data as described in this privacy notice; and
To the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation, or to establish, exercise or defend our legal rights.
We do not, and have not previously, sold your personal data to third parties.
Transfers of personal information to countries outside of the UK and/or European Economic Area (EEA)
Due to the international nature of our business, your personal data may be transferred to countries outside of the EEA, such as to jurisdictions where we or our clients conduct business or have a service provider, including countries that may not have the same level of data protection as that afforded by the EU General Data Protection Regulation or other data protection rules applicable to us (collectively, “Data Protection Law”). In these circumstances, we take steps to ensure that the recipient agrees to keep your information confidential and that it is held securely in accordance with the requirements of Data Protection Law, such as by requesting appropriate contractual undertakings in our legal agreements with service providers.
Retention of personal data
We will generally keep personal information about you for (A) as long as necessary in relation to the purpose for which it was collected, or (B) for a longer period if required under applicable law or necessary for the purposes of our other legitimate interests.
The applicable retention period will depend on various factors, such as any legal obligation to which we or our service providers are subject as well as on whether you decide to exercise your right to request the deletion of your information from our systems.
Your rights
You have certain rights under Data Protection Law in respect of the personal data we hold about you and which you may exercise. These rights are:
to request access to your information;
to request rectification of inaccurate or incomplete information;
to request the erasure of your information (a “right to be forgotten”);
to restrict the processing of your information in certain circumstances;
to object to our use of your information, such as where we have considered such use to be necessary for our legitimate interests (e.g. in the case of direct marketing activities);
where relevant, to request the portability of your information;
where you have given consent to the processing of your data, to withdraw your consent; and
to lodge a complaint with the competent supervisory authority.
How to contact us
If you have any questions about this Privacy Notice or requests with regards to the personal data we hold about you, you may contact us on info@cadwyncapital.com or by writing to 167-169 Great Portland Street, 5th Floor, London, W1W 5PF, UK.
Complaining to ICO
You have the right to complain to the Information Commissioner’s Office (ICO). Further information is available from the ICO’s website.