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PRIVACY POLICY

Background:

Aravis Capital Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About US

Aravis Capital Ltd.
Limited Company registered in England under company number 9919517.
Registered address: Rae House, Dane Street, Bishop’s Stortford Hertfordshire CM23 3BT.
Data Protection Officer: James Parker.
Email address: James.parker@aravis-capital.com
Telephone number: 020 3813 3110.
Postal Address: 720 Salisbury House, 29 Finsbury Circus London EC2M 5QQ

We are regulated by The Financial Conduct Authority

2. What Does This Notice Cover?

We may share your Personal Data with certain service providers who provide services for us or on our behalf, or who develop, host or maintain the Website. These service providers may be granted access to some or all of the Personal Data you provide or we collect. We may also use service providers to assist us in aggregating and anonymising such information, so that it does not include any information from which any individual can be identified. In circumstances where First Asset Finance plc (or any company within its group of companies) sells all or part of its business, your Personal Data may be transferred to the purchaser.

Your Personal Data may be transferred and stored outside the European Economic Area and be processed by staff who work for us or for one of our suppliers outside the European Economic Area. By submitting your Personal Data, you are agreeing to this transfer, storing or processing.

We want you to feel confident using this Website and otherwise dealing with us and we will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our site.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the GDPR, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
h) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
i) For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

5. What Personal Data Do You Collect

We may collect some or all of the following personal data (this may vary according to your relationship with us):
  • Name;
  • Business Address;
  • Business email address;
  • Business telephone number;
  • Mobile telephone number;
  • Business name;
  • Job title;
  • Details of your interactions with us, through our sales team. For example notes taken in meetings, emails with you and notes of phone calls. (All phone calls to and from our landlines are recorded)

Your personal data may be obtained from the following third party:

  • Prequin Limited;

6. How Do You Use My Personal Data

Under the GDPR, we must always have a lawful basis for using personal data. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

Your personal data may be used for one of the following purposes:

  • To register you as a new client.
  • To manage our relationship with you, which may include notifying you about changes to our privacy policy or asking you to leave a review.
  • To email monthly factsheets of our managers that we deem may be of interest to you
  • Personalising and tailoring our services for you.
  • Communicating with you. This may include responding to emails or calls from you.
  • Supplying you with information by email or post that we deem may be of interest to you. 

7. How Long Will You Keep My Personal Data?

 We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.

8. How and Where Do You Store or Transfer My Personal Data?

We share your data with external third parties, as detailed below in Part 9 that are based outside of the EEA. The following safeguard is applied to such transfers:

We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission.

Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

  • Access to your data is password protected and is stored within our CRM system managed by Satuit Technologies, Inc.
  • We undertake a regular audit of the data we hold on our database to ensure it remains relevant and necessary
  • We use a number of software firewalls to prevent unauthorised external access to data 

9. Do You Share My Personal Data?

We may share your personal data with other companies in our group for investment marketing purposes. This includes subsidiaries and/or our holding company and its subsidiaries.

We may sometimes supply your data to the investment funds in which you have an investment.

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR, as explained above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority. 

10. How Can I Access My Personal Data?

 If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within two weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of James Parker):
Email address: James.parker@aravis-capital.com
Telephone number: 44 20 3813 3110.
Postal Address: 720, Salisbury House, 29 Finsbury Circus London EC2M 5QQ.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website, www.aravis-capital.com