Cabot Square Capital LLP - Privacy Policy

  1. Introduction

    1. Who we are

      The Cabot Square Capital LLP website is brought to you by Cabot Square Capital LLP, a company incorporated and registered in England and Wales with company number OC318397 and registered office is at One Connaught Place, London, W2 2ET.

    2. Purpose of this Privacy Policy

      We take your privacy very seriously. As such, we ask that you read this Privacy Policy carefully as it contains important information about:

      • (a) what personal data we may collect from you;
      • (b) how we will use, store and protect your personal data;
      • (c) with whom we may share personal data; and
      • (d) your rights under relevant data protection laws.

      It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice 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 the other notices and is not intended to override them.

    3. Third party links

      The Cabot Square Capital LLP website may contain links to and from other applications, plug-ins and websites of other networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that they (and any services that may be accessible through them) have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these apps, websites or services. Please check these policies before you submit any personal data to these websites or use such services.

  2. Lawful basis for processing

    Under data protection laws, we must have a legal basis in order to process your personal data. The legal bases on which we may process your data are:

    • Consent: where you have consented for us to process your personal data for one or more specific reasons.
    • Performance of a contract: in order to perform a contract we may have with you.
    • Legal obligation: where processing of the data is required by law.
  3. What data we may collect from you

    We may collect and process the following personal data about you:

    • Identity data: first name, last name, title, gender.
    • Contact data: business address, email address and telephone numbers.
    • Profile data: your feedback and survey responses.
    • Technical data: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
    • Usage data: information about how you use our website.
    • Marketing and communications data: your preferences in receiving marketing from us and our third parties and your communication preferences.
  4. How we collect information from you

    We collect your personal data in a number of ways:

    • Automatically: as you browse the Cabot Square Capital LLP website certain information relating to your browsing patterns and technical data about the equipment you are using to access the website is automatically collected using cookies, server logs and other similar technologies. Please see our Cookie Policy for further information.
    • Directly: contact and identity data directly provided by you when you fill in online forms or correspond with us in any way, for example when:
      • applying for services;
      • submitting a query;
      • requesting or consenting to marketing materials being sent to you; or
      • providing us with feedback.
    • From third parties/public sources:
      • technical data may be obtained from the following parties:
        • (a) analytics providers such as Google based inside OR outside the EU;
        • (b) search information providers such as Google based inside OR outside the EU.
      • identity and contact data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
  5. How we use your personal data

    We may use your personal data for the following purposes:

    • to provide the requested services to you;
    • in accordance with our legitimate interests (in circumstances where your interests and fundamental rights do not override our interests);
    • to personalise your experience on the Cabot Square Capital LLP website;
    • to provide customer service, including to respond to your enquiries and fulfil any of your requests for information;
    • to send you important information regarding our services and/or other technical notices, updates, security alerts, and support and administrative messages; and
    • as we believe to be necessary or appropriate:
      • in order to comply with a legal obligation. This applies where the processing is necessary for us to comply with the law;
      • to enforce or apply this Privacy Policy; and
      • to protect our legitimate rights, privacy, property or safety, and/or those of a third party and your rights do not override those interests.
  6. Marketing

    It is important to us that we only provide you with tailored offers and promotions for services which you may want or need. You will therefore only receive such offers from us if you have consented to, and have not at any point opted out from, receiving marketing communications from us.

    Opting out from receiving marketing communications from us is easy and you may do so at any time by contacting us at optout@cabotsquare.com. We will process your request to be opted-out of marketing within 30 days of receipt.

    We will ensure that we obtain your consent before we share your personal data with any company outside of Cabot Square Capital LLP for marketing purposes.

    Where you opt out of receiving these marketing communications, we may still process your personal data for other required purposes, as specified in section 5 above.

  7. Retention of your data

    We will not retain your personal data for longer than is necessary for the purposes for which the personal data is processed. This means that your data will only be retained for as long as it is still required to provide you with services or is necessary for legal reasons. When calculating the appropriate retention period for your data, we consider the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed.

    When we determine that personal data can no longer be retained (or where you request us to delete your data in accordance with your right to do so (please see section 11 below for more information), we ensure that this data is securely deleted or destroyed.

    However, please note that, in some circumstances we may decide to retain your personal data for research or statistical purposes and, in such circumstances, we will anonymise your data before retaining it.

    For more details about our retention periods, please contact us at contact@cabotsquare.com.

  8. Accuracy of your data

    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.

  9. Security of your data

    In order to protect your personal data, Cabot Square Capital LLP has appropriate organisational and technical security measures. These measures include restricting access to your personal data to certain employees, ensuring our internal IT systems are suitably secure, and implementing procedures to deal with any suspected data breach.

    In the unlikely event of a data breach, we will take steps to mitigate any loss or destruction of data and, if required, will notify you and any applicable authority of such a breach.

    1. Transfer of your data to third parties

      There may be circumstances in which we may need to share your personal data with certain third parties, including third parties located outside of the EEA.

      The third parties to which we may transfer your personal data include:

      • IT services providers that are contracted by Cabot Square Capital LLP to provide IT systems and services as part of our normal business operations;
      • Fund administrators that are contracted by Cabot Square Capital LLP to provide fund administration services as part of our normal business operations;
      • Regulatory bodies that may demand information from us as part of their regulatory activities;
      • Auditors;

      The security of your data is important to us and we will, therefore, only transfer your data to such third parties if:

      • the third party has agreed to comply with Cabot Square Capital LLP’s instructions, required data security standards, policies, and procedures and put adequate security measures in place;
      • the transfer complies with any applicable cross border transfer restrictions and suitable safeguards have been put in place; and 
      • a fully executed written contract that contains suitable obligations and protections has been entered into between Cabot Square Capital LLP and the third parties.

      As mentioned above, we will only transfer your data where suitable safeguards have been put in place. These safeguards are intended to ensure a similar degree of protection is afforded to your data wherever it may be transferred and include:

      • only transferring your personal data to countries which have been deemed to provide an adequate level of protection for personal data by the European Commission;
      • where your data will be transferred outside of the EEA, entering into specific contractual terms which have been approved by the European Commission and which give personal data the same protection as within the EEA; or
      • where your data will be transferred to the US, ensuring that the third party to which we are transferring your data is part of the Privacy Shield.

      For more information on the safeguards used by Cabot Square Capital LLP when transfers of personal data to third parties, please contact us via the “Contact us” page at www.cabotsquare.com.

  10. Your rights

    You have certain rights in relation to the personal data we process and hold about you. These include:

    • Right to rectification: you have the right to require us to correct any inaccuracies in your data.
    • Right to erasure: you have the right to require us to delete your data, subject to certain legal requirements.
    • Right to restriction of processing: you have the right to require us to restrict the way in which we process your personal data. You may wish to restrict processing if, for example:
      • You contest the accuracy of the data and wish to have it corrected;
      • You object to processing but we are require to retain the data for reasons of public interest; or
      • If you would prefer restriction to erasure.
    • Right to data portability: you have the right to obtain from us easily and securely the personal data we hold on you for any purpose you see fit.
    • Right to object to processing: you have the right to require us to stop processing your personal data should you wish the data to be retained but no longer processed.
    • Right of access: you have the right to request access to personal data that we may process about you.
    • Right to withdraw consent: you have the right at any time to withdraw consent allowing us to process your personal data.

    If you would like to exercise any of the above rights, please:

    • put your request in writing;
    • include proof of your identity (such as a copy of your driving licence or passport) and address (such as a recent utility or credit card bill); and
    • specify the right you wish to exercise.

    Response time

    We will respond to requests made by you within one month.

    Charge

    We will not charge a fee for you to exercise any of the rights listed above.

  11. Cookies

    For more information about the cookies we use, please see our Cookies Policy.

  12. Amendments to this Privacy Policy

    No changes to this Privacy Policy are valid or have any effect unless agreed by us in writing. We reserve the right to vary this Privacy Policy from time to time. Our updated terms will be displayed on the Cabot Square Capital LLP website. It is your responsibility to check this Privacy Policy from time to time to verify such variations.

  13. Questions in relation to this Privacy Policy

    You should also be aware that you have the right to raise any concerns in relation to how we process your personal data to the Information Commissioner's Office (ICO).

    We have appointed a data privacy lead (DPL) who is responsible for dealing with any such concerns, in addition to overseeing questions in relation to this Privacy Policy and handling requests in relation the exercise of your legal rights. If you have any concerns, questions, or requests, please contact the DPL using the details set out below.

    Our full details are:

    Full name of legal entity: Cabot Square Capital LLP

    Name of DPL: Lawrence J Small, General Counsel

    Email address: lsmall@cabotsquare.com

    Postal address:

    Cabot Square Capital LLP
    One Connaught Place
    London
    W2 2ET

    Telephone number: +44 (0)20 7579 9320

Cabot Square Capital LLP

One Connaught Place
London, W2 2ET
United Kingdom

© Copyright 2018 Cabot Square Capital LLP