Shorelight Partners LLP, and their respective affiliates, (“Shorelight”) are committed to protecting and respecting your privacy.
This policy (together with our Terms of Use) and any other documents referred to on it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Please note, this website is not intended for children and we do not knowingly collect personal data relating to children.
Controller
Shorelight Partners LLP is the controller and responsible for your personal data (collectively referred to as “Shorelight”, “we”, “us”, or “our” in this privacy notice).
If you have any comments or questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:
Address: 2 Babmaes Street, St James’s, London SW1Y 6HD
Telephone: +44 (0) 20 3848 1550
Email: contact@shorelight-partners.com
You also have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Third-Party Links
Please note, this website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you.
Changes to our privacy policy and your duty to inform us of changes
This version was last updated on 24 May 2018. Any future changes we may make to our privacy policy will be posted on this page and, where appropriate, notified to you by e-mail.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Information we may collect from you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, transfer, store and process the following categories and types of personal data:
- Your name, title, date of birth and gender (Identity Data).
- Your address, email address and telephone number (Contact Data).
- Your bank account and payment card details (Financial Data).
- Details about investments you have made with us (Transaction Data).
- Your IP address, login data, browser type and version, and operating system and platform (Technical Data).
We may collect, use and share Aggregated Data such as statistical or usage data for any purpose. Aggregated Data is not considered personal data in law as this data does not directly or indirectly reveal your identity.
We do not collect any special categories of personal data such as data relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, health or sexual orientation. Nor do we collect any information about criminal convictions or offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from you and about you including through:
- Direct Interactions: This includes Identity and Contact Data you provide when you contact us by completing forms on our website, or by corresponding with us by email, telephone or post, for example to request further services or provide feedback.
- Automated technologies or interactions: As you interact with our website, we may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. As mentioned above, where we process aggregated, statistical data about our users’ browsing actions and patterns, it does not identify any individual and therefore does not constitute personal data.
In addition, our website uses cookies. Cookies are pieces of information that a website transfers to the cookie file on your computer’s hard disk. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies policy.
Third Parties: We may receive Identity and Contact Data from our third party affiliates who provides us with contact lists of potential investors who may be interested in our services and future investment opportunities. This information is used for marketing purposes only and we always provide the opportunity for you to opt-out (further information relating to our Marketing activity is set out below).
How we use your information
We will only use your personal data when the law allows us to. In most cases, the use, purpose and lawful basis for our processing is as follows:
Performance of a contract: we need to use your Identity, Contact and Financial Data for the purposes of carrying out our obligations arising from any contracts entered into between you and us. For example, to facilitate any investments you may make and to manage our relationship with you.
Necessary for our legitimate interests: we may use your Identity, Contact and Technical Data for ongoing business purposes, for example to ensure that content from our website is presented in the most effective manner for you and for your computer.
Compliance with a legal obligation: we use your Identity, Contact and Financial Data to comply with various legal obligations. For example, to notify you of changes to our terms or privacy policy.
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. You have the right to withdraw consent to marketing at any time by contacting us using the details set out above. If you would like further information about the specific lawful basis we rely on when using your personal data, please contact us using the details set out above.
Marketing
We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. As part of our ongoing marketing activity, we may use your personal data in the following ways:
- Promotions: We may use your Identity, Contact, and Transaction Data to form a view on what we think you may want, need or may be of interest to you. We do this in order to provide you with the most relevant investment opportunities.
You will only receive marketing communications from us if you have requested information from us, made previous investments, or if you have provided us with your details in order to receive marketing promotions and in each case you have not opted out of receiving communications from us.
Third Party Marketing: We will get your express opt-in consent before we share your personal data with any external company for marketing purposes.
Opting Out: You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time via the contact details below. When you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of previous transactions.
Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by an affiliate of us operating outside the EEA. Such affiliate maybe engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.
Whenever we transfer your personal data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
If you require further information on the specific mechanism used by us when transferring your personal data out of the EEA, please contact us using the details set out above.
Disclosure of your information
We may disclose your personal information to any member of our group, which includes our subsidiaries and members together with their respective affiliates, including subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
We may disclose your personal information to external third parties including professional advisers, such as lawyers and auditors who provide legal and accounting services, and service providers who provide administrative services. We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce other agreements.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only have process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data Retention
We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your personal data. Please see further information within Your Legal Rights section below.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your Legal Rights
Under EU data protection laws, you have the following rights in relation to your personal data:
- Right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Right to request correction or personal data that we hold about you. This enables you to have correct the personal data we hold if it is incorrect. Please note, we may need to verify the accuracy of the new details you provide to us.
- Right to request erasure of your personal data. This enables you to ask us to delete personal data where there is no good reason for us continuing to process it. This may also apply where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to delete your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Right to object to processing based on certain grounds. This enables you to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your personal situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process our information which override your rights and freedoms.
- Right to withdraw consent. This enables you to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
- Right to transfer data. This enables you to request the transfer of your personal data to you or a third party. We will transfer the data in a structured, commonly used, machine readable format. This right applies only in respect of automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of the above rights, please contact us using the above details.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We try to respond to all legitimate requests within one month but it may take longer if your request is particularly complex, in which case we will notify you and keep you updated. We may request specific information from you to help us confirm your identity and ensure your right to access the information, and to assist us in dealing with your request promptly.
