- Information we receive as part of our Research and Due Diligence processes ("Business Intelligence") on investment firms you manage or work for.
- Information you supply to AR as a client or prospective client.
The policy describes how AR collects, uses and processes your personal data, and how, in doing so, it complies with its legal obligations to you. Your privacy is important to AR, and the firm is committed to protecting and safeguarding your data privacy rights.
The EU General Data Protection Regulation (Regulation (EU) 2016/679) (together with applicable implementing laws, "GDPR") is applicable to the processing of personal data by AR and various undertakings appointed by it.
Contact details of data controller
1 Crown Square
Woking GU21 6HR
Please contact us with any queries or concerns regarding the handling of your personal data:firstname.lastname@example.org
What kind of personal data does AR collect?
Business Intelligence data: In order to assess the suitability of an investment, AR will collect data on the Key People at an Investment Firm such as name, email addresses, telephone numbers, biography, and previous employment.
Client data: In order to provide you with AR's services, it will be necessary for us to process certain personal information such as names, telephone numbers and email addresses.
How does AR collect Personal Data?
AR may collect personal data through a range of means. These may include:
- direct interactions (where you provide personal data to AR through telephone or email correspondence or other direct methods of communication);
- registration on our website;
- from third parties such as industry databases;
- other publicly available sources (such as websites (for example, LinkedIn) or publicly available registries (for example, FCA or other regulatory registers))
How does AR use your personal data?
Business Intelligence data: Your personal details are used by AR to produce reports requested by our clients.
Client data: Your personal details are held on secure servers for the purpose of contacting you in the course of supplying our services to you. We may contact you occasionally to offer additional services which we think may be of benefit to you.
Who does AR share your personal data with?
Business Intelligence data: Your personal data will be shared with clients and prospective clients, usually in the form of research and due diligence reports.
Client data: AR does not share client data with anyone else, unless required to do so by law.
Transfer of Personal Data outside the European Economic Area
AR may transfer and/or process your personal data outside the European Economic Area (the "EEA"). If AR transfers personal data outside the EEA, it will seek to ensure a similar degree of protection is afforded by ensuring that personal data is transferred only to persons in countries outside the EEA in one of the following circumstances:
- To persons and undertakings in countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- To persons and undertakings to whom the transfer of such personal data is made pursuant to a contract that is compliant with the model contracts for the transfer of personal data to third countries from time to time approved by the European Commission.
- To persons and undertakings based in the United States if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the United States.
How does AR safeguard your data?
AR has in place security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. These security measures include procedures to deal with any suspected personal data breach. AR will notify any affected person and any applicable regulator of any personal data breach in circumstances where they are required to do so by applicable law.
How long does AR retain your personal data for?
Business Intelligence data: To perform reliable due diligence, your personal data is retained indefinitely.
Client data: We retain your data for as long as you are a client or prospective client of AR. After that time, we retain it if AR believes in good faith that you may be interested in communications from us occasionally.
How can you access, amend or take back the personal data that you have given to AR?
You have various rights in relation to your personal data. To get in touch about these, please email email@example.com. AR will seek to deal with your request without undue delay, and in any event in accordance with the requirements of any applicable laws. Please note that AR will keep a record of your communications to help it resolve any issues which you raise.
You have the right to obtain information regarding the processing of your personal data and request access to any personal data concerning you that AR is processing. Whilst AR takes efforts to ensure that all personal data that it processes is accurate and up-to-date, you may ask AR to rectify any inaccurate or incomplete personal data concerning you and AR will do so without undue delay.
You have the right to withdraw your consent to the processing of your personal data at any time. Please note, however, that AR may still be entitled to process your personal data if we have another legitimate reason for doing so. For example, AR may need to retain personal data to comply with a legal obligation. You may, in certain circumstances, request that AR erase your personal data. You may also request that AR restricts, or you object to, AR's processing of your personal data if certain criteria apply. Please note that there may be circumstances where you ask us to erase your personal data, or where you object to or request we restrict, our processing of your personal data, but we are legally entitled to retain it. You have the right in certain circumstances to data portability. This means that, in those circumstances, you have the right to receive from AR any personal data concerning you in a structured, commonly used and machine-readable format, and may request that AR transmit it directly to another data controller, where technically feasible. Please note that this right only applies to personal data which you have provided directly to AR. Should you have any concerns about how AR processes your personal data you should contact AR at the email address above. You also have the right to lodge a complaint with the Information Commissioner's Office if you think that any of your rights have been infringed by us.
Incidental personal data processed via email
In the process of providing our service and information about AR, we may receive certain personal data, such as the name, address, email and/or telephone number or other contact of prospective clients. In such circumstances, the personal data of that contact may be retained on a general contact database that is maintained by AR, or in AR's email storage system, for as long as is necessary to process the personal data for the purpose for which AR is using it, or to comply with our legal obligations. Such personal data will only be processed by AR's employees in compliance with AR's data protection and data security policies and procedures.