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Privacy Policy

Mouro Capital I LP (“Mouro Capital”)

Privacy Notice

Last Updated 03 December 2020

 

This Privacy Notice (“Privacy Notice”) sets out how Mouro Capital  processes your personal data in connection with its business, including the provision of the Mouro Capital website at https://www.mourocapital.com (the “Site”), and carrying out our investment activities (“Investment Activities”).

This Privacy Notice applies to:

  • – visitors to the Site;
  • – personnel of suppliers of Mouro Capital;
  • – personnel, shareholders, partners and third party providers of companies in which we invest; and
  • – other third parties that we interact with during the day to day provision of our Investment Activities.

 

1. Purpose of this privacy notice

This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal data. This Privacy Notice also sets out your rights in respect of our processing of your personal data.

When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.

This Privacy Notice informs you of the nature of the personal data about you that is processed by us and how you can request that we delete it, update it, transfer it and/or provide you with access to it.

This Privacy Notice is intended to assist you in making informed decisions when using the Site and engaging with our Investment Activities. Please take a moment to read and understand it. It should be read in conjunction with our Terms of Use and our Cookie Policy.

This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).

 

2. About us

The Site and our Investment Activities are made available by Mouro Capital (“we”, “us, “our”). Mouro Capital is the data controller responsible for your personal data.

Mouro Capital I LP is, an English private fund limited partnership with registration number LP021083 and registered office at Eastcastle House, 27/28 Eastcastle Street, London, United Kingdom, W1W 8DH.

 

3. How to contact us

If you have any questions about this Privacy Notice or want to exercise your rights set out in this Privacy Notice, you can contact us by sending an email to [email protected]

 

4. What personal data we collect

In the course of providing you with Site and carrying out our Investment Activities, we may collect the following types of personal data about you:

  • Contact Data, such as your:
    • – name;
    • – address;
    • – email address;
    • – telephone number;
    • – social media handle; and
    • – the name of your organisation;
  • KYC Data, such as your:
    • – first name and last name;
    • – date of birth;
    • – gender;
    • – country;
    • – nationality;
    • – any additional KYC information that we may collect; and
    • – any other personal data you may provide when you invest or engage with us;
  • Payment Data, such as your:
    • – bank and account details; and
    • – information relating to a particular transaction;
  • Behavioural Data, such as:
    • – data relating to your browsing activity or interaction with our emails, through the use of cookies, pixel tags and other similar technologies; and
    • – when your current or previous sessions started.
  • Technical Data, such as your:
    • – IP address;
    • – browser type and operating system;
    • – geolocation, to ensure we’re showing you the correct notices and information; and
    • – any other unique numbers assigned to a device.

 

5. How we collect and receive personal data

We collect and receive personal data using different methods:

  • Personal data you provide to us

You may give us your personal data directly. This will be the case when, for example, you contact us with enquiries, visit our offices, subscribe to receive our marketing communications or provide feedback to us.

  • Personal data we collect using cookies and other similar technologies

When you access and use our Site, we will collect certain Behavioural Data or Technical Data. We collect this personal data by using cookies and other similar technologies (see the ‘Insight, analysis and retargeting through Cookies’’ section below).

  • Personal data received from third parties

From time to time, we will receive personal data about you from third parties. Such third parties may include analytics providers, data brokers, payment providers, hotel and transport providers and third parties that provide technical services to us so that we can operate our Site and carry out our Investment Activities.

  • Publicly available personal data

From time to time we may collect personal data about you (Contact Data or Profile Data) from publicly available sources (including open source data sets), media reports or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).

 

6. Who we collect personal data about

We collect and process personal data from the following people:

  • Site visitors

If you browse our Site, contact us with an enquiry through our Site, submit a complaint through our Site, we will collect and process your personal data in connection with your interaction with us and our Site.

  • Personnel, shareholders, partners and third party providers of entities we invest in.

If you are a member of personnel, a shareholder, partner or a third party provider for a start-up we invest in, we may collect and process your personal data in connection with these Investment Activities.

  • Visitors to our offices

If you attend any of our offices, we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when signing in as a guest. CCTV footage may also be collected for security purposes.  

  • Event attendees.

If you attend one of our events, we will process personal data about you in connection with your attendance at the event. For example, we may ask you to complete a registration or feedback form, or other document relating to the event.

  • Personnel that work for our partners and suppliers (including subcontractors).

If you (or your organisation) supply products or services to us or otherwise partner with us, we may collect and process your personal data in connection with our receipt of those products and services and/or partnership. This may include personal data included in any email or telephone communications or recorded on any document relating to an order for the products or services, such as your Contact Data.

  • Job applicants.

If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal data in connection with your application.

 

7. How we use your personal data

We use your personal data for the following purposes:

  • Use of our Site.

We collect and maintain personal data that you submit to us during your use of our Site in the following ways.

  • Your contributions to our Site and content that you allow us to post.

If you are featured in an article or post which we publish on our Site or via social media in relation to our Investment Activities, we may use your personal data (such as your Contact Details). If you provide photographs or other images in support of the article or post, we may publish one or more of those images alongside the article or post.

If you submit any other content to us, including via our Site, such as photographs, quotes or testimonials, we may process any personal data comprised within that content for the purposes of promoting our Site and Investment Activities.

We may also allow third parties to use the articles or posts that you feature in, (please see ‘Content requests’ below). If the use of such content would involve the use of your personal data, we may use your Contact Details to ask your permission to use the relevant content, unless we are satisfied that we have a lawful right to use the content without your permission.

Our legal basis for processing

Where we use content you are featured in, in connection with the Investment Activities, it is in our legitimate interest to use any personal data that you provide to us to ensure that we carry out the Investment Activities in an effective way.

Where we permit a third party to use your personal data contained within content that you are featured , we will do so without your permission if we are satisfied that it is within our or the third party’s legitimate interest to use your personal data, including to promote our Investment Activities or services offered by the third party. If it is not within our legitimate interest, we will contact you to ask your permission, in which case our processing of such personal data will be based on your consent.  

  • Linking to social media sites and interacting with our social media pages.

If you click on one of the social media links on our Site or otherwise interact with our social media pages such as on LinkedIn, Twitter or Medium (including interacting with any ‘like’ or similar embedded features on our Site or social media accounts) we and the relevant social media platform may receive information relating to such interaction and may share your personal data in connection with this purpose, such as certain Behavioural Data and Technical Data. For more information about how we use this personal data, please see the ‘Insight, analysis and retargeting through Cookies’ section below.

Please note that the relevant social media platform may also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform. 

Our legal basis for processing

It is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we provide the Site and carry out our Investment Activities in an effective way and to promote our Site and our Investment Activities via social media.

  • Carrying out our Investment Activities.

We collect and maintain personal data that you submit to us for the purpose of carrying out our Investment Activities. We may collect and process your personal data whether you are interacting with us on your own behalf or on behalf of any organisation you represent. We will collect and process your personal data if you are a member of personnel, a shareholder, partner or a third party provider for a start-up we invest in.

The personal data we process may include your Contact Data, Registration Data, and Payment data (where applicable). We process this information so that we can carry out our Investment Activities, maintain our user databases and to keep a record of how our Investment Activities are progressing.

If you attend one of our offices, we will process personal data about you which you volunteer in connection with your visit and any enquiries you may have. This will usually include your Contact Data, and any other personal data you volunteer. Some Investment Activities we carry out are also subject to separate terms and conditions which will also apply.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that we carry out our Investment Activities in an effective, safe and efficient way.

  • Hosting and managing events.

From time to time, we may organise and host events. We may process your Contact Data to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you.

If you attend one of our events, we may use your Contact Data and certain Profile Data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available.

Our legal basis for processing

It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.

We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your such personal data will be based on consent.

  • Surveys and feedback.

From time to time, we will invite you to provide feedback about us and/or our Site in the form of online/email surveys. We will collect and process your Contact Data, certain Profile Data, and any other personal data you choose to volunteer in your survey response or other feedback.

We use this information to help us to monitor and improve our Site, Investment Activities and offices, to assist with improving how we carry out our Investment Activities and training our personnel.

Our legal basis for processing

It is in our legitimate interest to use the personal data provided by you so that we can improve our Investment Activities and carry them out in an effective way.

  • Insight and analysis through Cookies

We and our third party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the device(s) that you use to access our Site  and emails that you receive from us). The data that is collected includes Behavioural Data and Technical Data, and certain Profile Data.

Please see our Cookie Policy for further information, including details of the third party partners that are used.

We and our third party partners use this data, in combination with your Contact Data, for the following purposes:

  • to analyse how you use, and the effectiveness of, our Site, including:
    • – to count users who have visited our Site or opened an email and collect other types of information, including insights about our visitors’ browsing habits, which helps us to improve our Site and the effectiveness of our emails;
    • – to measure the effectiveness of our content;
    • – to learn what pages of our Site are most attractive to our visitors, which parts of our Site are the most interesting and what kind of features and functionalities our visitors like to see; and
    • – to help us with the selection of future website design and to remember your preferences.

Our legal basis for processing

Where your data is collected through the use of non-essential cookies we rely on consent to collect your data. Please see our Cookie Policy  for further details.

However, we may rely on other legal basis when we use your personal data that has been collected via the use of Cookies for the purposes described in this section.

Where we use this personal data to analyse how you use our Site it is in our legitimate interest to use your personal data in such a way to improve our Site.

Advertising and Marketing activities

We carry out the following marketing activities using your personal data:

  • Email marketing

We use your Contact Details to send you (or the organisation you represent) marketing communications by email. You will be asked to subscribe to our newsletter through our website.

Our email communications will include press releases and any other information we may deem to be of interest to you, as well as general information about our organisation, our Site, our offices, the Investment Activities we carry out and the events and promotions we offer.

Our email marketing will include personalised and non-personalised email marketing. Personalised marketing is marketing which has been specifically tailored to you. For example, our personalised email marketing will feature Investment Activities and events that we think are most likely to appeal to you. Non-personalised marketing is marketing about our Investment Activities and events generally and is not tailored to any particular individual. 

Where we are sending you personalised email, we also use Behavioural Data and other information that we observe about you from your interactions with our Site, with our email communications to you, with the offices and/or with our Investment Activities in order to decide what sort of personalised marketing communications to send you. Please see the ‘Insight, analysis and retargeting through Cookies’ section above for more details about the personal data collected and how it is collected.

Our legal basis for processing

Where data that we process is anonymised, we do not require a legal basis to use it as the information does not constitute personal data. However, our collection and use of such anonymised information may be subject to other laws where your consent is required. Please see our Cookie Policy  for further details.

Where your personal data is not in an anonymous form (for example, your email address), it is in our legitimate interest to use your personal data for marketing purposes.

We will only send you marketing communications by email where you have consented to receive such communications, or where we have another lawful right to send such communications to you.

We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your Contact Data  to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.

The personal data we process may include your Contact Data  Registration Data, details of your education, qualifications and employment history, any other personal data which appears in your curriculum vitae or application, any personal data that you volunteer during an interview or your interactions with us, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

Our legal basis for processing

Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent. 

  • Receipt of services from suppliers

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to carry out our Investment Activities.

The personal data we collect from you may include your Contact Data and certain Payment Data, and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.

Our legal basis for processing

It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the services that you or your organisation provides, and carry out our Investment Activities, in an effective way.

  • Security

We have security measures in place at our offices, including CCTV and building access controls. There are signs in place showing that CCTV is in operation. The images captured are securely stored and only accessed on a need to know basis (e.g. to look into an incident). CCTV recordings are typically automatically overwritten after a short period of time unless an issue is identified that requires investigation (such as a theft).

We may require visitors to our premises to sign in on arrival and where that is the case we will keep a record of visitors for a short period of time. Our visitor records are securely stored and only accessible on a need-to-know basis (e.g. to look into an incident).

Our legal basis for processing

It is in our legitimate interests to process your personal data so that we can keep our offices secure and provide a safe environment for our personnel and visitors to our offices.

  • Business administration and legal compliance

We use your personal data for the following business administration and legal compliance purposes:

  • – to comply with our legal obligations;
  • – to enforce our legal rights;
  • – to protect the rights of third parties; and
  • – in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of all or a portion of our assets.

Our legal basis for processing

Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us such as a court order.

We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

  • Any other purposes for which we wish to use your personal data that are not listed above, or any other changes we propose to make to the existing purposes, will be notified to you using the contact details we hold for you.

 

8. If you fail to provide your personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to carry out the Investment Activities you have requested from us or to process an application for employment with us. In this case, we may have to cancel your application or the Investment Activities, in which case we will notify you.

 

9. How we obtain your consent

Where our use of your personal data requires consent, you can provide such consent:

  • – at the time we collect your personal data following the instructions provided; or
  • – by informing us using the contact details set out in the “How to Contact Us” section above.

 

10. Third party links and services

This Privacy Notice does not apply to your interaction with services provided by third parties.

  • Our Site may contain links to third party websites and services

When you use a link to go from our Site to another website (even if you don’t leave our Site), this Privacy Notice shall not apply to the processing of your personal data carried out by the relevant third party provider.

Your browsing and interactions on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. For example, our website provides links to relevant third parties who are involved in our Investment Activities. When you click on the links we provide to such third party website, you will be transferred from our website to the relevant third party’s website and the privacy notice (and other terms and conditions) of that third party will apply to you.

We do not monitor, control or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.

This Privacy Notice applies solely to personal data processed by us through your use of our Site, your involvement in our Investment Activities and/or in connection with our business operations. It does not apply to the processing of your personal data by these third party websites and third party service providers.

 

11. Sharing personal data

We will only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.

When processing your personal data, we may need to share it with third parties (including other entities within our group of companies) as follows:

Third-party organisations that provide applications/functionality, data processing or IT services: We share personal data with third parties who support us in carrying out our Investment Activities and help us provide, run and manage our internal IT systems. Such third parties may include, for example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy .

Payment providers and banks: We share personal data with third parties who assist us with the processing of payments and refunds.

Event partners and suppliers: When we run events, we will share your personal data with third-party services providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.

Third-party email marketing and CRM specialists: We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our email marketing communications and membership-related communications.

Recruitment agencies and related organisations: We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.

Auditors, lawyers, accountants and other professional advisers: We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

Law enforcement or other government and regulatory agencies and bodies: We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Sharing with other third parties: Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties in order to operate our Site, our offices and to carry out the Investment Activities.

 

12. Transfers outside the European economic area (“EEA”) and the UK

Where necessary in order to operate our Site and to otherwise carry out the Investment Activities, we will transfer personal data to countries outside the UK and the EEA.

Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data.

We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

When transferring your personal data outside the UK or the EEA, we will ensure that, where required by applicable law, at least one of the following safeguards is implemented:

Adequacy decisions: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. 

Model clauses: Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.

 

13. How long we keep your personal data

In respect of personal data that we process in connection with the Investment Activities, we may retain your personal data for up to six years from the date of supply of the Investment Activities and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.

In respect of any other personal data that we process, we will retain relevant personal data for up to three years from the date of our last interaction with you and in compliance with our data protect obligations. We may then destroy such files without further notice or liability.

If any personal data is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we will not retain it for longer than the period for which it is used by us.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future.

 

14. Confidentiality and security of your personal data

We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:

  • – unauthorised access;
  • – improper use or disclosure;
  • – unauthorised modification; and
  • – unlawful destruction or accidental loss.

All our employees and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above) who have access to and are associated with the processing of personal data are obliged to respect the confidentiality of the personal data of all users of our Site and involved in the Investment Activities.

 

15. Personal data of children

We do not specifically target our Site or Investment Activities at children. However, due to the nature of our organisation and the Investment Activities we carry out, we may from time to time collect and process personal data relating to individuals under the age of 18. Where we do so, we will comply with all applicable laws and regulations relating to the processing of personal data of minors. However, if you are under the age of [13/16/18], as applicable, you must ask a parent or guardian for permission before using our Site. If you are a parent or guardian, please supervise your child’s use of our Site.

 

16. How to access your information and your other rights

You have the following rights in relation to the personal data we hold about you. If you would like to exercise any of these rights, please contact us using the details set out in the ‘How to contact us’ section above.

Your right of access.

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

Your right to rectification.

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to erasure.

You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to data portability.

You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer it to a third party of your choice.

Your right to object. 

You can ask us to stop processing your personal data, and we will do so, if we are:

  • – relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
  • – processing your personal data for the purposes direct marketing.

Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section above or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.  

Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section above. You can also report any issues or concerns to a national supervisory authority in the Member State of your residence or the place of the alleged infringement. You can find a list of contact details for all EU supervisory authorities at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. As we are incorporated in the UK, our regulatory authority is https://ico.org.uk.

 

17. Changes to this privacy notice

We may make changes to this Privacy Notice from time to time

To ensure that you are always aware of how we use your personal data, we will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data. We may also make changes to comply with changes in applicable law or regulatory requirements.

We will notify you by e-mail of any significant changes to this Privacy Notice. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal data.