Dated: 17 April 2018
Protecting your data, privacy and personal information is very important to Clifford Street Capital LLP (“CSC”, “our”, “us” or “we”). This policy, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by CSC. Please read this privacy policy carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us. This privacy policy applies only to your use of our website at www.cliffordstreetcapital.com (our “Website”) or any contact you make with us by email, not to your use of any of the services we offer.
We may collect and process the following data about you:
The information you will be asked to provide us for these purposes will include your name, address, email address, phone number, job title and place of work.
Information that we may collect about others. We may collect and process personal data about others that you provide us with, including (but not limited to) information that you provide to us by filling in forms on our Website, or by email. This information might include, but is not limited to names, addresses, email addresses, phone numbers, job titles and places of work. You must have obtained clear permission from any individuals whose data you provide us with before sharing that data with us. For the avoidance of doubt, any reference in this privacy policy to your data shall include data that you have provided to us about other individuals.
Use of personal information under EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. The principal grounds that justify our use of your information include:
We use information held about you (and information about others that you have provided us with) in the following ways:
| Types of Information Collected | Uses of that Information | Use Justification |
|---|---|---|
| Name, email address, telephone number | For processing any enquiries made via our Website. | Legitimate interests (to provide you with information or a service you have requested) |
| Name, address, email address, phone number, place of work, job title, professional and educational history | To connect you to any of our portfolio companies. | Legitimate interests (to provide you with information or a service you have requested) |
We will not sell your personal data (or any other data you provide us with) to third-parties.
We may also disclose your personal information to third parties in the following circumstances:
| Purpose of disclosure and third party(s) to which disclosure might be made | Use Justification |
|---|---|
| We may disclose your name, address, email address, phone number, place of work, job title, professional and educational history to our portfolio companies. | Legitimate interests (to provide you with information or a service you have requested) |
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.
We will hold the above information for as long as necessary in order to deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body. We shall delete the personal data you share with us within 5 years. Some personal data may need to be retained for longer than this to ensure we can comply with applicable laws and internal compliance procedures. If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires. 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 anonymized (and the anonymized information may be retained) or securely destroyed.
Under the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at [email protected]. You have the following rights in relation to your personal data:
| Rights | Details |
|---|---|
| Right to Rectification | We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete. |
| Right to erasure / ‘Right to be forgotten’ | Asking us to delete all of your personal data will result in us deleting your personal data without undue delay (unless there is a legitimate and legal reason why we are unable to delete certain of your personal data, in which case we will inform you of this in writing). |
| Right to restriction of processing | You have the right to ask us to stop processing your personal data at any time. |
| Right to data portability | You have the right to request that we provide you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so. We provide tools and custom reports for you to easily collate and download information which you submit whilst using our Website. |
| Right to complain | You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk). Although we encourage our customers to engage with us in the event they have any concerns or complaints. |
CSC will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs. Where you request CSC to rectify or erase your personal data or restrict any processing of such personal data, we may notify third parties to whom such personal data has been disclosed of such request. However, such third party may have the right to retain and continue to process such personal data in its own right, for example to comply with their legal obligations.
Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. We therefore encourage you to review it from time to time to stay informed of how we are processing your information.
Questions, comments and requests regarding this privacy policy are welcome and should be addressed to Nolan Grills. For the purpose of the relevant data protection legislation, the data controller is Clifford Street Capital LLP with registered address at Third Floor, 7/8 Savile Row, London, W1S 3PE.