Privacy Policy
Effective date: 24th January 2020
Introduction
Welcome to Goldbourne Capital’s privacy policy.
Goldbourne Capital Ltd (“Goldbourne", "we", "us" or "our") respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website www.goldbournecapital.com (“website”) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Section 1 - Important information and who we are
Purpose of this privacy policy
This privacy policy describes how we collect, store, disclose and process personal data that we obtain through your use of this website, in connection with your use of our services, or when you otherwise contact us by telephone, email, letter and/or we collect your personal data.
Our website is not intended for children, nor do we provide services to children. However, children may be named as beneficiaries in some situations, in which case we will collect limited personal data about them.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
For the purposes of the European General Data Protection Regulation 2016/679 (the “GDPR”), Goldbourne is the “controller” of, and responsible for, your personal data.
Contact details
If you have any questions about this privacy policy or our privacy practices, please contact us using the contact details below:
Full name of legal entity: Goldbourne Capital Ltd
Email address: chris.cylwik@goldbournecapital.com
Postal address: 15 Bowling Green Lane, London, EC1R 0BD
Telephone number: 07855 773607
You 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.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review and we reserve the right to change, modify and update this privacy policy from time to time by posting a revised version on our website and, if considered necessary, we will notify you directly. Therefore, we recommend you regularly consult this privacy policy, to make sure that you are aware of any changes. This version was last updated on the date show at the top of this privacy policy. 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.
Section 2 - The data we collect about you
“Personal data”, or “personal information”, means any information about an individual from which that person can be identified directly or indirectly, by reference to an identifier such as their name, identification number, location data, online identifier or one or more factors specific to them. Personal data does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
IDENTITY DATA - includes first names, maiden name, last name, marital status, title, date of birth, gender, passport and company details.
CONTACT DATA- includes address, email address and telephone numbers, and emails and records of meetings and telephone conversations.
FINANCIAL DATA - includes bank account details (including personal bank details and bank details of sole traders etc.) and bank statements.
TRANSACTION DATA - includes details about your accounts, payments made to and from you, and transactional behaviour.
ONBOARDING INFORMATION - includes credit reports, due diligence information and anti-money laundering reports.
MARKETING AND COMMUNICATION DATA - includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any SPECIAL CATEGORIES OF PERSONAL DATA about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Section 3 - How is your personal data collected?
We use different methods to collect data from and about you including through:
DIRECT INTERACTIONS. You may give us your Identity, Contact and Financial Data by corresponding with us by meeting, post, phone, email or otherwise. This includes personal data you provide when you:
engage with us regarding our services;
request marketing to be sent to you;
give us feedback or contact us.
THIRD PARTIES OR PUBLICLY AVAILABLY SOURCES. We will receive personal data about you from various third parties and public sources as set out below:
Identity Data from third parties who recommend you to us for our services;
Identity, Onboarding Information and Contact Data from publicly available sources such as Companies House, HMRC and the Electoral Register and other organisations’ websites, credit reference providers, law enforcement agencies and fraud prevention bodies.
Section 4 - How we use your personal data
We will only use your personal data when the law allows us to. 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 obligation.
Where you have given your consent.
Purposes for which we will process your personal data
We have set out below, in a table format, a description of all the ways we plan to process your personal data, and which legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose 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 where more than one ground has been set out below.
Purpose/Activity - To register you as a new customer/client
Type of data
(a) Identity
(b) Contact
(c) Onboarding Information
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
Purpose/Activity - To provide our services to you:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
Type of data
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us and to deliver marketing materials)
Purpose/Activity - To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
Type of data
(a) Identity
(b) Contact
(c) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Purpose/Activity - To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data
(a) Identity
(b) Contact
(c) Onboarding Information
Lawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
Purpose/Activity - To make suggestions and recommendations to you about services that may be of interest to you
Type of data
(a) Identity
(b) Contact
(c) Marketing and Communications
Lawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Section 5 - Disclosures of your personal data
There are circumstances where we wish to disclose or are compelled to disclose your personal data to third parties. This will only take place in accordance with the applicable law and for the purposes listed in this privacy policy.
We may share or disclose your personal data to following third parties:
Our affiliated companies and offices.
Our professional advisors, such as our auditors, accountants and lawyers.
Trusted third-party service providers who perform services on our behalf in connection with our services. The services provided by such third parties include services in the following categories: processing payments on our behalf, sending marketing communications on our behalf, authenticating identities on our behalf, helping us to create or maintain our databases, helping us to research or analyse visitors to our website and maintaining the security of our cloud-hosting services, backend support services and data analysis and visualization support services.
Another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganization, change of legal form, dissolution or similar event.
A successor organization or other legal entity, in the case of a merger, financing, acquisition or dissolution, transition, or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. We do not guarantee that any entity receiving your information in connection with one of these transactions will comply with all of the terms of this privacy policy following such transaction. However, it is our practice to seek reasonable protection for personal data in these types of transactions.
Public authorities, regulatory bodies and other third parties, to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, or to protect our rights, property or safety or the rights, property or safety of our customers or others (e.g., to a reporting agency for fraud protection). We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.
Any other third party where you have provided your consent
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.
Section 6 - International transfers
Where we transfer European Economic Area personal data to a third party located in a country not recognized by the European Commission, or another relevant body, as ensuring an adequate level of protection, we will take appropriate steps, such as implementing Standard Contractual Clauses recognized by the European Commission, to safeguard such personal data.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Section 7 - 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 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.
Section 8 - Data retention
How long will you use my personal data for?
We will store your personal data for no longer than is necessary for the purpose for which such personal data is processed. Please note, however, that we may retain and use your personal data as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements and rights, or if it is not technically and reasonably feasible to remove such information from our databases.
Section 9 - Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data – specifically:
REQUEST ACCESS TO YOUR PERSONAL DATA. You may have the right to request access to any personal data we hold about you as well as related information, including the purposes for processing the personal data, the recipients or categories of recipients with whom the personal data has been shared, where possible, the period for which the personal data will be stored, the source of the personal data, and the existence of any automated decision making.
REQUEST CORRECTION OF YOUR PERSONAL DATA. You may have the right to obtain without undue delay the rectification of any inaccurate personal data we hold about you.
REQUEST ERASURE OF YOUR PERSONAL DATA. You may have the right to request that personal data held about you be deleted.
REQUEST RESTRICTION OF PROCESSING YOUR PERSONAL DATA. You may have the right to prevent or restrict processing of your personal data.
REQUEST TRANSFER OF YOUR PERSONAL DATA. You may have the right to request transfer of your personal data directly to a third party where this is technically feasible.
RIGHT TO OBJECT. You may have the right to object to the processing of your personal data when you have legitimate reasons to do so.
RIGHT TO WITHDRAW CONSENT. Where processing is based on consent, you may have the right to withdraw such consent. In some cases, if you withdraw your consent to use of your personal data, we may not be in a position to continue to provide our services or products to you.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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 could refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.