CONNECTED CAPITAL PRIVACY POLICY

WHO WE ARE AND IMPORTANT INFORMATION

Introduction

This is the privacy policy (the “Privacy Policy”) of Connected Capital (“Connected Capital LLP”) of Lansdowne House, 57 Berkeley Square, London, W1J 6ER.  This policy shall include any subsidiaries and affiliates and so when we refer to “We”, “Us”, or “Our” in this Privacy Policy, We are referring to how Connected Capital is responsible for processing data. This policy also outlines what information we collect and how we look after your personal data when you directly interact with Us or visit our website at www.connected-capital.com (the “Site”).

This Privacy Policy is for all individuals and entities we have interaction with, which will include Professional Investors, Corporate clients and representatives, external service providers and vendors and our clients (collectively, “you”). 

Purpose

The Privacy Policy outlines how we collect, hold, use and disclose your personal data. This data may have been provided by you when:

(1)    Fill out our online contact form on our Site;
(2)    Correspond with Us;
(3)    Contact us to enquire or purchase our services.

Our site is ONLY intended for Professional and Institutional investors and NOT intended for Children. We do not knowingly collect data relating to children. 

Controller
We have appointed a data protection officer (the “DPO”) who is responsible for our Privacy Policy and overseeing the any queries in relation to the Privacy Policy. If you have any queries please contact the DPO by sending an email to info@connected-capital.com.

Third-Party Links 
In some cases, we may provide links on the Site to third party websites for your convenience or to provide further information. We endeavour to select the most appropriate websites to link with; however, we do not control the content of their websites, do not endorse them and cannot accept liability for the content, product offerings or the availability of those linked websites. Clicking on the links may allow third parties to collect or shared data about you. We do not control these third party websites and are not responsible for their privacy statements. 

Changes to this policy
This policy has been updated on 25th May. The policy may be updated at our discretion from time to time in view of our data protection requirements, regulatory obligations, changes in our practices or any changes in the applicable law.


WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

We may collect, use, store and transfer different types of personal data about you which are as follows:

1. In a direct interaction from you during the course of delivering a product or service

(a)    “Identity Data” includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, age and gender, photographs, job title, national insurance number, passport number, Tax identification number/s, nationality, driving license, images of passport, driving license, signatures, photographs;

(b)    “Contact Data” includes registered or residential address, telephone number, email address, social media identity, telephone number;

(c)    “Financial Data” includes bank account details, financial accounts, product information; 

(d)    “Transactional Data” includes details on payments to us, you and any other third party institution involved in the transaction, and details of the product or service you may purchased from us;

(e)    “Employment Data” includes role, position names and duration of employers past and present, employers address, employers telephone number, email address, website, sector;

2. On our site when you visit our website

(a)    “Anonymous Technical Data” includes IP addresses, cookies, activity information, geo location, device identification, operating system identification, browser identification and activity on our site.

HOW WE USE YOUR PERSONAL DATA, PURPOSES AND LEGAL BASIS

1.    On-boarding a new client: In our normal day to day interaction with clients in meeting our requirements for compliance with legal obligation under a contract with you, for the detection or prevention of crime including fraud as required under our regulatory obligations and permissible under law.

             a.    Legal basis: Meeting internal compliance requirements, regulatory requirements of Know Your Client (KYC), Anti Money Laundering (AML), counter terrorist financing laws;
             b.    Types of Data: Identity Data, Contact Data

2.    Processing Order and Payments: In processing and delivering your order, in payment of fees and in collection of money owed to Us.
             a.    Legal basis: In relation to performance of a contract with you and required to recover any debts due;
             b.    Types of Data: Identity Data, Contact Data, Financial Data, Employment Data and Transactional Data.


3.    Relationship Management: Day to management of our relationship with you.
             a.    Legal Basis: In relation to performance of a contract with you, Compliance with legal, regulatory requirement obligations, to keep our records accurate and updated.
             b.    Types of Data: Identity Data, Contact Data

4.    Administration: For day to day administration of our business
             a.    Legal basis: Prevention of fraud and any necessary legitimate interest of the business.
             b.    Types of Data: Identity Data, Contact Data

5.    Site effectiveness: Data Analytics for Improvement in content, measurement in effectiveness of our products, services and navigation.
             a.    Legal basis: Necessary legitimate Interests to study customer demand for our products/services and to grow our business
             b.    Types of Data:  Anonymous Technical Data

Marketing
From time to time we will send communication of new products and services only if you have requested the information or an existing client who has purchased goods and services from us. We may use Identity Data, Contact Data and Transactional Data to determine what We think may interest you. 

Third-Party marketing
We do not share any data with a company outside Connected Capital for Third-Party marketing purposes.

Cookies
We may track and process information and data in relation to your use of our site using “cookies”. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this website and on others. Most Internet browsers allow you to stop receiving cookies via options/settings.

Data collected from website users is processed anonymously. We only use cookies to monitor the performance of our website and to improve visitor experience only.

DISCLOSURES OF YOUR PERSONAL DATA

We may have to disclose your personal data with parties and purposes as stated below:

1.    Government, Regulatory, Legal or another regulated entity, government agencies when it has been requested or is required for the purposes to meet regulatory obligations of a reporting a suspected or an actual incident breach of regulatory regulation;
2.    With banks, lenders, financial intermediary, financial advisors, lawyers, other advisors;
3.    Any relevant authority for the purposes of prevention, investigation, detection or prosecution of criminal offences in addition to prevention of threats to public security as applicable by law;
4.    Credit agencies and debt-collection agencies;
5.    Payment and shipping services providers;

Data Security
We take reasonable steps to keep your personal data safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to risks inherent in processing personal data. 

Data Accuracy
We take reasonable steps to ensure that your Personal Data that we process is accurate and where applicable kept updated. 

Data Retention
We only retain your personal data as required to fulfil the purposes outlined above including any obligations for legal, accounting or reporting requirements from regulatory authorities and/or government agencies. We are required to keep basic information about our customers for seven years, after they cease to be customers, for tax purposes. 

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data, which include:
1.    Right to request access to, or copies of, your Personal Data that we process or control, with disclosure to the nature and processing;
2.    Right to request rectification of any inaccuracies in your Personal Data we Process or control;
3.    Right to request erasure or restriction of your Personal Data that we Process or control;
4.    Where we Process your Personal Data on the basis your consent and right to withdraw;
5.    You have the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk) or to any equivalent body in the relevant jurisdiction. At the first instance we would appreciate the chance to deal with your concerns before you approach the Information Commissioner’s Office so please contact us on the details provided above in the first instance. 


To exercise one or more of the above rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided above.