Precede Capital Privacy Notice

v1.0 2021-03-01

 

Introduction 

At Precede Capital Partners Limited, we and our affiliated undertakings (“Precede Capital Partners Limited”, “we”, “us” and/or “our”) value the relationship we have with you.  Protecting the confidentiality and integrity of personal data is a critical responsibility that Precede Capital Partners Limited takes very seriously. 

This Privacy Policy explains how we collect, use, share, store and otherwise process your personal data when you use this website (the “Website”) or we otherwise receive your personal data in connection with our relationship with you or the business you work for.  It also explains your rights under applicable data protection laws, including the European Union’s  (“EU”) General Data Protection Regulation (“GDPR”) and the United Kingdom’s (“UK”) Data Protection Act 2018 (the “Data Protection Laws”). 

Where the Data Protection Laws apply to the processing of your personal data, the controller for your personal data is Precede Capital Partners Limited, unless we advise you otherwise. The controller decides how personal data about you is processed. 

We keep this Privacy Policy under regular review and we will advise you of any updates or changes to this Privacy Policy, from time to time.  

1. 
   

   Information we collect from you and how we use it  

We regularly collect personal data in the context of our business activities. The types of personal data relating to you that we may collect, and the purposes for which we process this data, depends on the nature of your interaction with us.  

We collect personal data that you provide to us in the following ways:  

• When you communicate with us through the Website: we collect personal data when you provide it to us through communications via our Website. This includes where you have contacted us through the “Contact” page on the Website.  

• Automated technologies and/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. 
• When you provide services to us: when you enter into a contractual agreement with us to provide us with a service, we may collect certain details in respect of you or other representatives of your business. 

• When you request information or provide us with information in connection with a product or service: we may receive personal data from you in connection with a Precede Capital Partners Limited product or service which you are interested in. 

• Events: when we arrange or attend events, we may collect your personal data when you attend the event and exchange your details with us (for example, by providing your business card). 

• Careers: we may collect personal data from you when you enquire or apply for a vacancy with us. 

The personal data we collect may include: your personal details (such as your title, full name); contact details (such as, email address, physical address, location, telephone number); employment details (such as, your company, job role, business card details); information from identity documents (such as, passport, driving license, work permit, visa, other photo identification, other immigration documentation); curriculum vitae (such as, qualifications, previous employment history and profession activities); results of background checks (such as, references, qualifications, and to the extent permitted by law, criminal background checks (unspent convictions)). 

2. Why we collect your personal data  

Under Data Protection Laws, we are required to specify the legal basis under which we are allowed to process your personal data.  Generally, we may process your personal data to perform a contract with you or for your benefit, for the establishment, exercise or defence of legal claims or proceedings and to comply with our legal and regulatory obligations, for our legitimate interests or when we have your consent. 

The purposes we process your personal data include the following: 

• to enable us to carry out our obligations arising from our engagement with you or to take steps to enter into an agreement with you (please note that where you enter into a loan or an investment with us, we will issue you with a separate privacy notice which details how we handle your personal data); 

• to enable us to respond to an enquiry or other request you make when you contact us via our website or directly and to improve the quality of our communications and interactions with our visitors; 
• to notify you about changes to our products and/or service; 
• to protect the security of and managing access to our premises, IT and communication systems, online platforms, website and other systems, preventing and detecting security threats, fraud or other criminal or malicious activities;  
• to comply with our legal and regulatory obligations and requests, including reporting to and/or being audited or investigated by national and international regulatory bodies; 
• to comply with court orders and to exercise and/or defend our legal rights;  

• to understand how you visit our website, how you interact with us and to enrich your user experience, and to customise your relationship with us; 
• to send you event invitations, business updates, or other marketing materials, and ensuring the efficient management of events and to promote our business and relationships; 
• for our recruitment, when you apply for a job role with us.  Ensuring potential recruits of any kind are appropriately qualified for positions at the firm. We may use information collected throughout the recruitment process to review Precede Capital Partners Limited equal opportunities profile in accordance with applicable laws. We may also need to review your right to work in line with applicable laws.  

When we rely on our legitimate interests to process your personal data, we do so to maintain business relationships and communicating with you as a business contact and to generally manage our business operations. We consider that reliance on our legitimate interests are in compliance with Data Protection Laws.  

3. Cookie Policy

Please refer to our Cookie Policy. 

4. Marketing

We may use your personal data to develop, manage and market products and services to meet your needs and to provide you with information on our products, services, events that you request from us or which we feel may interest you. We may contact you by SMS, post, e-mail or telephone unless you have told us that you do not wish to receive marketing communications from us. Where we are required by applicable laws, we will obtain your prior consent before contacting you. We will not sell or otherwise share your personal data with third parties, other than as stated within this privacy notice. 

 

You have the right to opt out of receiving marketing at any time by following the information in each communication on how to unsubscribe or by writing to us at: enquiries@precedecapital.com. 

5. How We Share Your Personal Data

We share your information as follows: 

• Third party service providers: Third parties who provide services to us have access to your personal data, for example, we engage providers for website analytics, hosting and cloud computing services and other IT services, background and AML checks, administration of loan products, talent management and recruitment services, marketing services, facility agent and security agent services, in addition to other administrative services.  
• Event co-hosts. We may share limited personal data (name, title, employer) with co-hosts of events we host or otherwise sponsor in order to administer the event and provide a list of attendees. 
• Administrative and legal reasons. We may disclose personal data as we deem necessary and appropriate under applicable laws, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process; in response to lawful requests by public, governmental and regulatory authorities. 

• Business transfers. We may disclose and transfer your information and data to a third party: (a) if we assign our rights regarding any of the information to a third party or (b) in connection with a corporate merger, consolidation, restructuring, sale of certain of our ownership interests, assets, or both, or other corporate change, including without limitation, during the course of any due diligence process. 
• Precede Capital Partners Limited entities. When using your personal data for the purposes described above, we may share your personal data with other Precede Capital Partners Limited entities. 
• Third party investors and co–lenders. We may disclose and transfer you information and personal data to a third party co-lender or investor in respect of a loan product offered to you or to Precede Capital Partners Limited. 

6. Data Transfers

The personal data that we collect from you may be stored in the United Kingdom and/or European Economic Area (“EEA”) as well as being transferred to a destination outside the EEA, such as to the United States. This location may not provide the same protections as the data protection laws in the United Kingdom and/or EEA. Where the country we transfer your personal data to outside the EEA is not already recognised by the European Commission as providing adequate protection, where required, we will implement appropriate safeguards (such as the European Commission approved standard contractual clauses) to govern such transfers, pursuant to applicable data protection laws. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. If you require further information, please contact us at  privacy@precedecapital.com.  

7. Retaining Your Personal Data

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws or until you withdraw your consent (where applicable). To determine the appropriate retention period for your 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 use your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data. 

8. Protecting Your Personal Data

We use a variety of technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data, in accordance with our internal security procedures and applicable law. Personal data may be stored on our own technology systems or those of our service providers or in paper files. 

We also train and instruct our employees that all personal information must be handled in accordance with this Privacy Policy and applicable privacy and data protection laws, and any misuse by employees is subject to disciplinary action. 

9. What are your rights?

You have the following rights with respect to your personal data: 

• 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 need to charge a reasonable fee. 
• Right to correct or request deletion: You may ask us to correct, delete or remove your personal data. 
• Right to object to or restrict processing:  You may object to the processing of your personal data and, where you consented to processing, you may withdraw your consent.  You may also ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest its accuracy or object to us processing it. If you exercise your rights, we will respect your decision in accordance with our legal obligations. 

• Right to data portability: You have the right to receive personal data in a structured, commonly used and machine-readable format and (if certain conditions are satisfied), transmit that personal data to a third party, if we have the technical means. 
• Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to your local data protection authority. We hope you will be able to address any concerns with us directly in the first instance so we are able to respond to them. 

In the limited circumstances where the individual may have provided their consent to the collection, processing and transfer of personal data for a specific purpose, the individual has the right to withdraw consent for that specific processing at any time. To withdraw consent, please use the details provided in the “Contact Us” section below. 

You may exercise your rights under Data Protection Laws by contacting us as indicated under the ‘How to Contact Us’ section below. 

10. How To Contact Us 

If you have any questions about our Privacy Policy, or if you would like to access personal data we hold about you or exercise your other rights under the applicable law, you can contact us at privacy@precedecapital.com. 

 

Last updated: 16 March 2021