Longmead Capital take clients’ privacy very seriously and our privacy notice below provides full details about how we collect, use, share and manage and store data.
PRIVACY NOTICE FOR CLIENTS
Longmead Capital Limited is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you.
Longmead Capital Limited, “The Company” collects, stores and processes personal data relating to its clients in order to manage the business relationship. This privacy notice sets down how the Company collects and uses personal information about you during and after your working relationship with us.
This privacy notice applies to current and former clients. This notice does not form part of a business contract.
The Company is committed to protecting the privacy and security of your personal information. The Company is committed to being clear and transparent about how it collects and uses that data and to meeting its data protection obligations.
- Data Protection Principles
The Company will comply with data protection law. This means that the personal information we hold about you must be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have explained to you clearly and not used in any way that is incompatible with these purposes;
- Relevant to the purposes we have told you about and limited to those purposes only;
- Accurate and kept up to date;
- Kept only for such time as is necessary for the purposes we have told you about; and
- Kept securely.
- What Information Does the Company Collect and Process?
The Company collects and processes personal data as part of its customer due diligence requirements. Personal data means any information about an individual from which the person can be identified. This includes:
- Personal contact details, such as your name, title, address and contact details, including email address and telephone number;
- Photograph on an official document which confirms your identity (passport)
- Date of birth;
- Tax status and national insurance number;
- Information about your marital status, next of kin, dependants and emergency contacts;
- Information about your nationality
The Company collects this information directly from you as a client.
Data is stored on a secured server.
- Why Does The Company Process Personal Data?
The Company needs to process data to ensure that we are complying with our legal obligations as part Money Laundering Regulations and Know Your Customer.
- Situations In Which We Will Use Your Personal Information
Situations in which we will process your personal information are listed below:
In order to:
- Execute the contractual agreements with have you as a client as part of our core business activities;
- To inform associated third parties who have a legitimate interest and specifically for ‘Know Your Client’ and ‘Ultimate Beneficial Owner’ requirements.
- Change of Purpose
The Company will only use your personal information for the purpose for which it was collected unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will advise you of this and explain the legal basis which allows us to do so.
You should be aware that we may process your personal information without your knowledge or consent where this is required or permitted by law.
- How We Use Sensitive Personal Information
We do not envisage that we will hold sensitive personal information.
- Information About Criminal Convictions
We do not envisage that we will hold information about criminal convictions.
- For How Long Do You Keep Data?
The Company will only hold your personal data for as long as is legally required to fulfil the purposes we collected it for, including any legal, accounting or reporting requirements.
- Who Has Access to Data?
Your information is only accessible to the shareholders and held on a secure server.
The Company shares your data with third parties where required by law, where it is necessary in order to administer the working relationship with you or where we have another legitimate interest in doing so.
The Company will not transfer your data to countries outside the European Economic Area
- How Does The Company Protect Data?
The Company takes the security of your data seriously. The Company has internal policies and controls in place to prevent your data being lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties. Details of these measures are available on request.
When the Company engages third parties to process personal data on its behalf, they do so on the basis of written instructions, under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.
- Your Duty to Inform Us of Changes
It is important that the personal information we hold about you is accurate and current. Please be sure to keep us informed if your personal information changes.
- Your Rights
As a data subject, you have a number of rights. You can:
- access and obtain a copy of your data on request (known as a “data subject access request”);
- require the Company to change incorrect or incomplete data;
- request erasure of your personal information. This enables you to ask the Company to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the Company is relying on its legitimate interests as the legal ground for processing; and
- ask the Company to suspend the processing of your personal data for a period of time if data is inaccurate or there is a dispute about its accuracy or the reason for processing it.
If you would like to exercise any of these rights, or you have any questions about the privacy notice, please contact either James Brackenbury or Shilen Patel.
If you believe that the Company has not complied with your data protection rights, you have the right to make a complaint to the Information Commissioner’s Office.