(a) Personal information we may collect about you
(b) How we use your personal information and who we may disclose it to
(c) Transmission, storage and security of your personal information
(d) Your rights and contacting us
(e) Our Cookies policy
(f) Third Party Websites
PERSONAL INFORMATION COLLECTION
We may collect and process the following personal information about you:
(a) Information you provide to us – personal information that you provide to us, for example during the onboarding of new clients and If you send us a CV in relation to a possible position at Quilam Capital Limited, including your name, email address (and/or proof of address), other contact details and financial information;
(b) Our correspondence – information about any correspondence that we may have with you, including when you contact us via the “contact us” links on the websites;
(c) Website and communication usage – details of your visits to the websites and information collected through cookies etc. including, but not limited to, your IP address and domain name, your browser version and operating system, traffic data, location data, web logs and other communication data, and the resources that you access.
INFORMATION USE AND DISCLOSURE
Under EU data protection law, we must establish and inform you of the legal basis or “ground” for our use of your personal information. Use of personal information under EU data protection laws must be based on one of a number of legal “grounds”. The principal legal grounds that may apply to our use of your information are:
• Consent: where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use)
• Contract performance: where your information is necessary to enter into or perform our contract with you.
• Legal obligation: where we need to use your information to comply with our legal obligations.
• Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
• Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
For each use of personal information mentioned below, we note the purpose for which we use and disclose it, who we may disclose it to, and the grounds we use as a basis for our use.
(a) To provide our services and conduct our business which may include passing your data to third parties such as administrators, agents or contractors or to our advisors (e.g. legal, financial, business or other advisors);
Use basis: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you).
(b) In relation to fraud prevention – we and other organisations may access and use certain information to prevent fraud as may be required by applicable law and regulation and best practice at any given time. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them.
Use basis: legal obligations, legitimate interests (to ensure that you fall within our acceptable risk profile and to assist with the prevention of crime and fraud), consent (where this includes health data, or data relating to ethnic or racial origin, political affiliations)
(c) For research and development purposes to analyse your personal information in order to better understand our clients needs and to develop our business. This may involve transferring your personal information to third party service providers;
Use basis: legitimate interests.
(d) To inform you of changes;
Use basis: legitimate interests
(e) To ensure website content is relevant and presented in the most effective manner for you and for your device;
Use basis: consent, contract performance, legitimate interests.
(f) To reorganise or make changes to our business – In the event that we are: (i) subject to negotiations for the sale of our business or part thereof to a third party; (ii) sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process or transferred to that re-organised entity or third party and used for the same purposes as set out in this policy or for the purpose of analysing any proposed sale or re-organisation.
Use basis: legitimate interests (in order to allow us to change our business)
(g) In connection with legal or regulatory obligations we may process your personal information to comply with our regulatory requirements, which may include disclosing your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world.
Use basis: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)
If you send us an email through the “Contact Us” button part of this Site, we will use the personal data provided to contact you and respond to your query. If you send us a CV in relation to a possible position at Quilam Capital Limited, we will use the information provided to match you with current or future opportunities and contact you.
By providing us with your e-mail address you consent to our using the e-mail address to provide you with e-mail alert services. If at any time you do not wish to be contacted by us by e-mail please use the link provided on any e-mail sent to you to de-register. Alternatively, write to the Compliance Officer at our registered office.
No data transmission over the Internet or website can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information in accordance with data protection legislative requirements. All information you provide to us is stored and used subject to our security policies and standards.
We will retain your personal information for as long as is necessary for the purposes for which they were collected and any other permitted linked purposes. So if personal information is used for two purposes, we will retain it until the purpose with the longest retention period expires; but we will stop using it for the purpose with a shorter retention period once that shorter period has expired.
We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed.
We may sometimes transfer your personal information to third parties in countries outside the European Economic Area (the EEA) in which data protection laws may be of a lower standard than in the EEA. When we do so, we will use appropriate safeguards to protect the personal information that we transfer. We will either ask for your consent to the transfer or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient, unless we are permitted under applicable data protection law to make such transfers without such formalities (including where the export is to a country that has been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore where no further safeguards are required in order to export to that country).
LINKS TO OTHER WEBSITES
A cookie is simply a bit of data stored on a user’s hard drive which contains information about the user. When the user closes their browser, the cookie will terminate. The cookie we use is essential for parts of this Site to work. You may delete and block all cookies from this Site, but it may mean that parts of this Site may not work. Most web browsers allow some control of most cookies through the browser settings. For further information on cookies please go to www.allaboutcookies.org.
RIGHT OF ACCESS
Data protection legislation gives you the right (subject to some exceptions) to access certain personal information held about you, correct any inaccuracies and to prevent the processing of your personal information that is likely to cause unwarranted substantial damage or distress to you or anyone else and to object to any decision that significantly affects you being taken solely by a computer or other automated process. If you wish to know what personal information Quilam Capital Limited holds on you, you may obtain it by contacting us at the address set out below. If it transpires that the information held is inaccurate, we will make the necessary amendments and confirm to you that these changes have been made.
To prevent unauthorised access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we receive via the contact us email on the website. However, no security system can be completely secure.
Accordingly, we cannot guarantee the complete security of your personal information. Please exercise caution when determining what personal information you disclose via this Site.
How to contact us:
Quilam Capital Limited
49 Albemarle Street