Albourne Privacy Policy and Processing Notice

Last Updated 2 January 2024

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 more specific privacy notices indicated below and 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 where required.

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. Where applicable, 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”).

Where required, 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Data, including the GDPR and the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation together with any and all other applicable privacy laws and standards in those jurisdictions in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 Personal Information

Personal 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”), during any visit by you to any Albourne office and/or in any communication between you and Albourne personnel. This information includes the following categories and types of personal data:

• Identifying Personal information such as 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;
• Internet or other electronic network activity information, such as your browsing history, and information regarding your interaction with an Albourne website or app; 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).

If you are an individual associated with an investment management company or a fund, please also see the “Information for Fund Managers” located at:

https://www.albourne.com/moatspace/managerinformation

for a more detailed privacy notice and information on the categories of personal information Albourne collects about you and your firm’s executives and other key employees in connection with Albourne’s due diligence of investment vehicles and associated management companies.

Under GDPR, we process your personal data for the purposes as disclosed to you 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 and due diligence business and Albourne’s offices security and safety.

Additionally, Albourne will process personal data fairly and in accordance with Applicable Data Laws. In particular, and to the extent required by Applicable Data Laws, 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:

• If you are a potential or existing client, in the course of carrying out due diligence in order to achieve a sufficient level of knowledge and understanding of a prospect or client and its business, management and employees. 
• If you are an individual associated with an investment management company, 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 concerning the categories of personal information collected and the use of such information for investment managers are found at: https://www.albourne.com/moatspace/managerinformation.
• If you are a client or investment manager to provide investment advisory, due diligence and risk advisory services to Albourne clients.
• To prevent fraud.
• If you are potential or existing client, to check your identity 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.
• If you are a potential or existing client, 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.
• If you are a potential or existing client, to build up marketing profiles, aid strategic development and analyze/audit usage of any Albourne Website.
• To maintain and operate Albourne’s IT systems and Albourne Websites.
• If you are a potential or existing client, for the marketing of Albourne’s services. See more details below.
• If you are a supplier or visitor to Albourne offices, for safety and security purposes.

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 understand how you use Albourne’s Website. This helps us to provide you with a smooth experience when you visit the Albourne Website, and also allows us to improve the site. A cookie is a small text file that can be placed on your computer or other device when using the Albourne Website.

We set first party cookies on Albourne web pages. We also use third party cookies via Google Analytics and HubSpot to optimize the Albourne Websites and to make them more relevant to your interests. Here is a link to Google’s Privacy page, where further information can be found under the header "How Google uses data when you use our partners’ sites or apps” located at https://policies.google.com/technologies/partner-sites. You can learn more about HubSpot cookies, by visiting the “Cookies set in a visitor's browser by HubSpot” at https://knowledge.hubspot.com/privacy-and-consent/what-cookies-does-hubspot-set-in-a-visitor-s-browser.

What do we use cookies for?

We use two kinds of cookies:

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. We also 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.

Analytics Cookies – We use Google Analytics and HubSpot cookies to record your visit to the Albourne Website, the pages you have visited and the links you have followed. We will use this information to optimize the Albourne Website and make it more relevant to your interests. We collect this data by setting Google Analytics and/or HubSpot cookies on your device. If you are an approved Insights User, we may use this information to e-mail you about services and products that are more targeted to your interests if you have provided consent to those e-mails. 

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

Please note that if you decide to disable or block strictly necessary cookies, parts of the Albourne Website may not function correctly or at all. Should you choose, however, to disable or block strictly necessary 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. You may also use the Cookies Banner to manage your cookies preferences, and registered users may separately indicate their preferences. Alternatively, you can visit www.aboutcookies.org or www.youronlinechoices.eu for comprehensive information on how to manage cookies. Please note that Albourne does not recognize Do Not Track browser settings at this time. For more information, please visit our Cookies Page, by clicking here: www.albourne.com/albourne/cookies

Marketing

Albourne’s research and services are available to institutions, not to individuals.  If you are a potential Albourne client (e.g., an investor) 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,  

https://village.albourne.com/village/login if you are a Village User, and   

https://www.albourne.com/albourne/userpreferences if you are an Insights 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 or your ordinary place of residence (“Your Home Country”) which do not provide the same level of data protection as the EEA or Your Home Country. This includes transfers the object of which is (i) to enable information to be accessed by Albourne personnel located outside the EEA or Your Home Country 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 or Your Home Country, where applicable. 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, and in the case of a Albourne client, 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. For more information, please refer to Information Security Policy Statement (albourne.com)

Retention Albourne will not keep personal data for longer than necessary and will dispose of any such data securely.

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 or any alternative method described below.

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.

Notice for California Residents

For United States residents in California, personal data or personal information has the meaning given in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (the “CCPA”). 

We will collect, store, use and disclose personal data in accordance with the CCPA.

The categories of personal information we may collect and process are highlighted in more detail above and include (to the extent not excluded due to being publicly available):

• Personal identifiers, like name, Internet Protocol address, email address
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our Websites
• Geolocation data.
• Professional or employment-related information
• Inferences drawn regarding your preferences

If you are a potential job candidate for Albourne’s U.S. offices, please refer to the more detailed privacy policy at  https://www-us.albourne.com/albourne/privacypolicycalifornia for additional information on the categories of personal information Albourne collects about you in connection with your potential employment.

The CCPA may provide you with the following rights. 

• Information.  You can request information about how we have collected, used and shared your personal information during the past 12 months.  To do so, please visit: http://www.albourne.com/albourne/ccpa/information.
• Access.  You can request a copy of the personal information that we maintain about you.  To do so, please visit: http://www.albourne.com/albourne/ccpa/access.
• Deletion.  You can ask us to delete the personal information that we collected or maintain about you.  To do so, please visit:  http://www.albourne.com/albourne/ccpa/delete.
• Correct.  You can ask us to correct inaccurate personal information that we collected or maintain about you.  To do so, please visit:  http://www.albourne.com/albourne/ccpa/correct.
• Opt-out of sale of your personal information.  If we sell your personal information, you can direct us to stop selling your information.  To do so, please visit: http://www.albourne.com/albourne/ccpa/optout.  
• Nondiscrimination and nonretaliation.  You have the right not to receive discriminatory treatment for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain information in response to an access request and limiting the circumstances in which we must comply with a deletion or correction request.  If we deny your request, we will communicate our decision to you. You will not receive discriminatory treatment by Albourne for the exercise of rights conferred to you by the CCPA.

To request access to or deletion of personal information:

o   visit the websites referred to above

o   call 1-888-687-7963

o   email us.legal@albourne.com

To opt out of sale of your information visit California Residents – Do Not Sell My Info at http://www.albourne.com/albourne/ccpa/optout.  Please note that Albourne does not sell the personal information of visitors to albourne.com, nor does it engage in cross-context behavioral advertising, as defined by the CCPA.  Where Albourne collects your sensitive personal information, it is not for the purpose of inferring characteristics about you. 

Identity verification. For certain requests, the CCPA requires us to verify the identity of the individual submitting the request before providing a substantive response to the request.  We may verify your identity by asking you to provide at least two personal data points to see whether it matches the data points maintained by Albourne, which we have determined to be reliable for the purpose of verifying your identity.  Depending on the sensitivity of the personal information at issue, we may require that you sign a declaration under penalty of perjury that you are a CA resident whose personal information is the subject of the request. 

Authorized agents.  California residents can empower an “authorized agent” to submit requests on their behalf.  We will require the authorized agent to have a written authorization confirming that authority if you decide to use an authorized agent.

Do Not Track
Please note that we do not support “Do Not Track” browser settings at this time.

Retention
Albourne considers a number of factors in its evaluation of the retention period for your personal information.  These include, but are not limited to, applicable law and policy that may apply to the data.  Albourne will not keep personal information for longer than necessary and will dispose of any such data securely.  

Children
Albourne Websites are not intended for minors under the age of 18.

Contact
For questions regarding Albourne’s privacy policies and practices, please contact 1-888-687-7963 or e-mail us.legal@albourne.com.