We are committed to protecting your personal information and ensuring we respect your privacy. This Privacy Notice explains how we will look after and use any personal information that we collect about you.

Personal information means any information about you from which you can be identified. Examples of personal information include your name, home address, national insurance number, date of birth, telephone number and e-mail address but it also includes other pieces of information which can be used to identify you, either directly or indirectly, such as a cookie.

Strangford Capital Limited is the Controller of the personal information you provide to us. If you have any questions about this Privacy Notice or the information we hold about you please contact us using the details set out below:

Full name of legal entity: Strangford Capital Limited
Email address: info@strangfordcapital.com
Postal address:  Garvey Studios, 14 Longstone Street, Lisburn, Co. Antrim, Northern Ireland, BT28 1TP

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. We would however appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

We collect information in the course of providing our financial services to you. The information which we collect, use, store and transfer about you are:

• Employment details (job title, company name, address etc.)
• Documentary data (things can include passport or drivers licence or other forms of identification)

We do not collect any special categories of personal data. 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 or biometric data.

Where we need to collect your personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to provide the goods or services you asked for. In this case we may have to cancel the product or services but we will tell you if this is the case.

Typically we will collect information from you when you contact us directly or provide information in order for us to provide our products and services. We collect information from and about you in the following ways primarily through direct interactions when you give us your personal information by filling in forms, during correspondence or other interactions with us.

We only obtain, use and keep personal information where we need it for a specific purpose. We set out in the table below the ways in which we plan to use your personal information. We are only able to use your personal information if we have a proper legal reason or basis for doing so. This is called a legal basis and the regulations require that we have a legal basis so that your privacy is protected. Most commonly we will use your information in the following ways:

• We have a contract with you. For example, as a client of ours.
• We have a legal obligation. We need to use your personal information to comply with laws that assist in the prevention of financial crime and to comply with regulatory obligations. For example this might include confirming your identity and source of wealth, as well as ensuring we provide you with necessary information so you understand the risk of the financial services we can provide.
• We, or a third party, have a legitimate interest in processing the information and your interests and fundamental right do not override those interests. For example, processing your information to source deals.

We set out in the table below all the ways we plan to use your personal information and the legal bases we rely on to do so. We also explain what our legitimate interests are where appropriate:

Purpose

Lawful basis for processing

• We process the personal data of our investors (or their employees and senior management) and the employees and managers of our corporate finance clients in order to facilitate corporate finance and investment advisory services.
• (If you have a contract with us) Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
• We process the personal data of our investors (or their employees and senior management) and the employees and managers of our corporate finance clients in order to facilitate corporate finance and investment advisory services.
• (If you do not have a contract with us) Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• We process the personal data of our service providers (or their employees and senior management) in order to give effect to our contracts with them, and monitor their work as per the terms of our contracts with them.
• Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
• We process the personal data of a wide variety of business contacts for the purposes of conducting key parts of corporate finance business. Generally, we will store this data, and may use it to communicate with the data subjects at appropriate points in time.
• Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
• We process personal data of all parties (or their employees and senior management) with whom we have a business relationship in order to comply with our KYC and customer due diligence obligations.
• Processing is necessary for compliance with a legal obligation to which the controller is subject.

We may need to provide information to third parties for a variety of reasons, for example, we may need to provide information to assist in the detection or prevention of crime or for the purpose of safeguarding national security. Please refer to the table in the section ‘How we will use your personal information’ which explains how we use your data. The third parties we share your information with are as follows:

• Service providers such as compliance consultants, lawyers, accountants and fund administrators

The regulations which have been put in place to protect your privacy apply throughout the EEA. The EEA is the European Economic Area which includes all the countries in the European Union plus Iceland, Liechtenstein and Norway. This means that any country within the EEA must meet the same privacy standards as the United Kingdom. All the personal information that we hold about you will be processed in the EEA.

The period for which we will retain personal information will vary depending on the purposes that it was collected for, as well as the requirements of any applicable law or regulation. When we decide how long we will retain your personal information, we will take into account the amount, nature, sensitivity of your information and how we want to use it as well as the potential risk of harm being caused from unauthorised use or disclosure. We review our retention periods for personal information on a regular basis and will ensure all records are safely destroyed if we no longer need to retain them or you have contacted us to request so.

You are provided with a number of different rights under the data protection laws in relation to your personal information. These allow you:

• To access your information;
• To request we correct your information;
• To request that we erase your information;
• To object to the processing of your information;
• To request a restriction in the processing of your information;
• To request a transfer of your information;
• To complain to the Information Commissioner’s Office; and
• To withdraw your consent.

If you wish to exercise any of these rights please contact info@strangfordcapital.com. Please note that you will not have to pay a fee to access your personal information or to exercise any of the other rights. We may, however, charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or we may refuse to deal with your request. We may also need to seek further information from you to confirm your identity before we release any personal information. This does not affect your right to make a complaint.