Privacy Statement



Albourne Privacy Policy and Processing Notice

Last Updated April 2019

Thank you for visiting https://www.albourne.com/. We are committed to protecting and respecting your privacy.

This Privacy Policy and Notice (“Privacy Statement”), together with any terms and conditions that are applicable to your relationship with Albourne (as defined below), sets out the basis on which any personal data we collect from you (“you”, “your”, or “user”), or that you provide to us, will be processed by us. When used in this Privacy Statement, the terms “Albourne”, “we”, “our” and “us” mean Albourne Partners Limited and all of its subsidiaries and its or their branches.

In respect of your personal data, Albourne Partners Limited, 16 Palace Street, London, SW1E 5JD Tel +44 (0)207 346 7000, is the data controller.

Please read the following carefully to understand what personal data we collect, how that personal data is used and the ways it can be shared by us and you. IF YOU DO NOT ACCEPT AND AGREE WITH THIS PRIVACY STATEMENT THEN YOU MUST NOT ACCESS ANY ALBOURNE WEBSITE.

Albourne Websites (as defined below) may, from time to time, contain links to and from the websites of third parties and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Personal data


In accordance with this Privacy Statement, Albourne may collect, use and process your personal data (including your special category data and data relating to criminal convictions and offences), together with other information, for the uses set out below. For the purposes of this Privacy Statement “processing”, “transferring”, “personal data”, “special category data” and “data relating to criminal convictions and offences” shall be interpreted in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”).

We will collect, store, use and disclose personal data in accordance with all applicable laws relating to the protection of Personal Data, including the GDPR and the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation together with any and all other applicable privacy laws and standards in those jurisdictions in which Albourne operates (together “Applicable Data Laws”).

Collection of information


Information may be collected from you in the course of your use of any website or application owned or operated by us (each an “Albourne Website”), and/or in any communication between you and Albourne personnel. This information includes the following types of personal data: contact data such as name, job title, company name, company address, phone and fax number, home address and phone number, mobile telephone number, company or personal e-mail address, and market research data such as readership patterns which may be through/from the registration forms completed by you, from your details provided to us, and/or from your employer.

If you are an Albourne client, prospective Albourne client or a fund manager we may also collect information about you from company and trade registers, and other publicly available sources. We may also request information on you from third parties. We may then combine this information with any information you give to us and other information we collect about you. We will use this information and the combined information for the purposes set out below (depending on the types of information we receive).

We process your personal data only:

  • if you have consented to us doing so;
  • if we need it to perform a contract which we have entered into with you;
  • if we need it to comply with a legal or contractual obligation; or
  • if we have a legitimate interest which is not overridden by your interests or fundamental rights and freedoms. Such legitimate interests may be in connection with Albourne’s investment advisory business.

Albourne will process personal data fairly and in accordance with Applicable Data Laws. In particular, Albourne will ensure that your personal data is:

  • used lawfully, fairly and in a transparent way;
  • collected only for valid purposes that Albourne has clearly explained and not used in any way that is incompatible with those purposes;
  • relevant to the purposes notified to you and limited only to those purposes;
  • accurate and kept up to date;
  • kept only as long as necessary for the purposes Albourne has told you about; and
  • kept securely.

Special category data and data relating to criminal convictions and offences


To the extent we have a business need to collect your special category data and data relating to criminal convictions and offences for the purposes set out below, and are permitted to do so by local laws, we may collect and use your special category data and data relating to criminal convictions and offences. If we do so, and are required by local laws, we will contact you to obtain your consent for this collection and use in advance. You may withdraw your consent at any time by sending a request to the Personal Data Protection Officer at dataprotection@albourne.com.

Uses of personal data


Albourne may use your personal data for any of the following purposes:

  • In the course of carrying out client due diligence in order to achieve a sufficient level of knowledge and understanding of a prospect or client and its business, management and employees.
  • In the course of carrying out fund manager due diligence in order to achieve a sufficient level of knowledge and understanding of a fund manager and its business, management and employees. Additional details for fund managers are found here.
  • To provide investment advisory, due diligence and risk advisory services to its clients.
  • To prevent fraud.
  • To check the identity of prospects and new clients and to prevent money laundering.
  • To disclose it to its service providers, professional advisers and agents, where necessary.
  • If you have registered for this purpose, to review whether you are a suitable candidate for any job opportunities within Albourne.
  • Occasionally, to trace debtors.
  • To record and monitor for internal Albourne purposes your use of any Albourne Website.
  • For internal administrative or training purposes.
  • For responding to subpoenas, court orders or regulatory or legal requirements.
  • To provide you with personalised service, processing client orders, registrations and enquiries, conducting market research surveys, running competitions, and providing you with information about products and services we offer (providing you agree to receive such information). If you wish to receive such information, please indicate your preferences using the consent boxes provided on the registration pages.
  • To build up marketing profiles, aid strategic development and analyze/audit usage by aggregating and anonymizing information so that no individual user is identified.
  • To maintain and operate Albourne’s IT systems and Albourne Websites.
  • For the marketing of Albourne’s investment advisory services. See more details below.

YOUR RIGHTS  

If you are located in the European Economic Area (“EEA”), you have a number of rights in relation to how we process your personal data. These include:

  • the right to access the personal data that we may hold about you;
  • the right to rectify any inaccurate personal data that we may hold about you;
  • the right to have your personal data erased in certain circumstances, for example, where it is no longer necessary for us to process your personal data to fulfil our processing purposes; where you object to your data being processed on certain grounds (for example, for marketing purposes); or where your personal data is being unlawfully processed; and
  • the right to have your data ported to a new service provider if you no longer wish to use the Albourne Website or our services.

You can exercise any of these rights any time by contacting our Group Personal Data Protection Officer at dataprotection@albourne.com.

If you are located outside of the EEA, you may have similar rights, which are also exercisable by contacting us.

COOKIES  

We use cookies to distinguish you from other users of the Albourne Website. This helps us to provide you with a smooth experience when you visit the Albourne Website, and also allows us to improve the Albourne Website.  A cookie is a small text file that can be placed on your computer or other device when using the Albourne Website.

We set cookies (first party cookies) on web pages. We also use Google Analytics (third party cookies) on https://www.albourne.com/ to optimise the Albourne Website and make it more relevant to your interests. Here is a link to the site "How Google uses data when you use our partners' sites or apps located at www.google.com/policies/privacy/partners/.

What do we use cookies for?

The cookies we use are of two kinds:

  1. Strictly Necessary cookies - These cookies are used for technical reasons and are necessary to enable the Albourne Website to operate efficiently, so that you can navigate the Albourne Website with ease and use specific features. They include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Albourne Websites may not operate effectively. Please note that we use session cookies where necessary to keep you logged into the Albourne Website for the duration of the session, and these cookies are deleted when you close the web browser.
  2. Analytical - These cookies record your visit to the Albourne Website, the pages you have visited and the links you have followed. We will use this information to optimise the Albourne Website and make it more relevant to your interests. We do not share this information with third parties.

How do I control my cookie settings on my computer or device?

Please note that if you decide to disable or block cookies, parts of the Albourne Website may not function correctly or at all. Should you choose however to disable or block our cookies on your computer or other device you will need to do this through your browser. Click on the 'Help' menu on your browser to learn how to manage your cookie preferences. Alternatively, you can visit www.aboutcookies.org or www.youronlinechoices.eu for comprehensive information on how to manage cookies.

Marketing

Albourne may contact you by mail, telephone, fax, e-mail or other electronic messaging service with offers of Albourne’s services, materials, news, training or events that may be of interest to you. If you do not wish to receive such information from Albourne, or you have changed your mind, please email your wishes to dataprotection@albourne.com.  If you register with an Albourne Website, options to opt-in to such communications are offered to you there. By opting-in and providing Albourne with your contact details, you consent to being contacted by those means for those purposes. If you do not wish to receive such information from Albourne, or you have changed your mind, and wish to change your privacy settings, please visit https://village.albourne.com/castle/profile, if you are a Castle User or https://village.albourne.com/village/login for Village Users or https://www.albourne.com/albourne/freeparking/profile, if you are an Investor Portal User. Albourne will never pass your contact details on to a third party for direct marketing purposes.

Other countries

Albourne operates as a global business and may have a business need to transfer your personal data to countries outside the EEA which do not provide the same level of data protection as the EEA. This includes transfers the object of which is (i) to enable information to be accessed by Albourne personnel located outside the EEA who need to know the information in order to do their jobs; and/or (ii) to enable information to be accessed by Albourne clients located outside the EEA. We have put terms in place to ensure that your information is adequately protected and your privacy respected in the case of such a transfer.

Other individuals

Please note that, when you give us information about another individual for business purposes, including their personal data (which may include special category data and data relating to criminal convictions and offences), you warrant and represent that the other individual has (i) given permission for you to do so, (ii) consented to our processing of his or her personal data for the purposes set out in this Privacy Statement, (iii) consented to the transfer of his or her personal data abroad in accordance with this Privacy Statement, and (iv) consented to your receiving, on his or her behalf, any data protection notices from Albourne.

Monitoring of communications

To ensure that Albourne follows your instructions correctly and to improve our service through training of its staff, Albourne may monitor any communication between you and Albourne.

How we protect your Personal data

People  We educate our employees to treat personal information and personal data with care. They are required to limit their access to information that they need to perform their jobs, such as to conduct our business, operate the Albourne Website, service your account or help you pursue your financial objectives. All our employees are required by contract and Albourne’s policies to keep all personal information secret, confidential and secure, and must take particular care not to disclose it to any other person (whether inside or outside Albourne) unless there is a legitimate Albourne business need and they are authorised to do so.

Procedures In compliance with applicable laws and regulations, we maintain physical, electronic and procedural safeguards to protect your personal information. In addition, we have put in place Data Transfer Agreements (based on approved EEA model clauses) between those Albourne companies located in the EEA and those located outside the EEA to govern the transfer of data outside the EEA. These terms ensure that personal data and information is adequately protected within Albourne and that individuals’ privacy is respected.

Security  We take such security measures as we deem appropriate and proportionate to keep all information (including personal data) confidential and secure against unlawful processing and to prevent loss, destruction or damage.

Amendments and queries


If your personal details change please amend them by editing your details within the Albourne Website, or contact village-registrations@net.albourne.com or contact your Client Account Manager.

If you have any questions about how Albourne uses your personal information, please email dataprotection@albourne.com.  If you are an individual located in Singapore and have a query in relation to the Personal Data Protection Act in Singapore, please contact Debra Ng at +65 6536 9541.

Under local laws, you may be entitled to ask for a copy of your personal data. Please also address any such requests to dataprotection@albourne.com.

Should you have cause to complain about how we handle your personal data, please contact us in the first instance. We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to the applicable data protection authority in the country in which you are located.  For EEA users, this is the UK Information Commissioner’s Office (ICO): https://ico.org.uk/concerns/ or https://ico.org.uk/global/contact-us/.


Any changes we make to this Privacy Statement will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Statement. If we intend to use, process, or disclose personal data for purposes materially different than those described in this Notice, we will inform you before proceeding with the use, processing, or disclosure.