1. WHO WE ARE
This website is operated by Dalmore Capital Limited (the “Manager”). Dalmore Capital Limited is referred to in this Privacy Notice as “us” or “we” and you can contact us using the details set out in paragraph 9 below.
As data controllers we are committed to protecting the personal data we hold on any individuals by ensuring that your personal data is treated with care and is not processed in an unlawful manner. We are committed to protecting your privacy and complying with the UK General Data Protection Regulation.
This Privacy Notice describes the types of personal data which we collect and the uses which we make of it.
2. WHAT IS PERSONAL DATA?
Personal data includes information relating to natural persons who:
can be identified or who are identifiable, directly from the information in question; or
who can be indirectly identified from that information in combination with other information.
Personal data includes all information held in electronic form or manually in a structured filing system and includes name, date of birth, gender, nationality, address, contact information, IP address, images, such as from CCTV, etc.
3. WHAT PERSONAL DATA DO WE COLLECT?
We hold personal data which you provide to us – for example, by contacting us via the contact details on our website or in pursuit of business activities. We may collect and process the following data about you:
If you contact us, we may keep a record of that correspondence including personal identified and contact details;
Information that you may provide to us in relation to any business matters e.g. contact details, passport details;
Information that you may provide to us in relation to business operations with us including for HR purposes e.g., name, address, email address, gender etc.
There may also be cases where personal data comes from other sources e.g. details of professional experience from publicly accessible online profiles, personal data from our business partners and other third parties
4. PURPOSES FOR WHICH PERSONAL DATA IS USED
We use personal data, to provide services or information to you and, where necessary for other legitimate business interests, including for the administration of our business or to prevent fraud.
5. THE LEGAL BASES WE RELY ON
The law permits businesses to use personal data where one or more conditions to usage set out in the GDPR applies. We generally rely on the following lawful grounds for processing your personal data:
Legitimate interests: where we use your data for the purposes of our legitimate interests as a business in a way which might reasonably be expected as part of running our business or as set out in our privacy notice from time to time, and where such usage does not materially impact your rights, freedom or interests.
Contractual obligation: where processing is necessary for fulfilling our obligations under a contract with you.
Legal obligation: where processing is necessary to comply with legal obligations.
In limited circumstances, we may request your consent to use your personal data.
6. DISCLOSURE OF PERSONAL DATA
We may share your personal data with the following third parties or categories of third parties:
Our legal advisors;
Our service providers for HR purposes;
Auditors for our corporate and fund entities;
Banks and other lenders;
The administrator of our fund entities;
Our IT service provider; or
The depositary for our manager alternative investment funds.
7. INTERNATIONAL DATA TRANSFERS
While processing your personal data, certain personal data may be transferred to, or accessed by, entities situated or operating in territories outside of the UK or the EEA.
These territories may not always offer a level of protection for the rights and freedoms of data subjects which is equivalent to the data protection standards afforded within the UK and the EEA. Where personal data is transferred to third parties in territories that do not have equivalence status, we will seek to ensure that the data is protected and transferred in a manner consistent with any applicable legal requirements. We will ensure suitable safeguards are in place to protect the privacy and integrity of your personal data. Such safeguards include carrying out a data transfer risk assessment (including a risk assessment of the laws of the destination country) and entering into Standard Contractual Clauses with the entity established outside of the UK or the EEA (as applicable).
8. RETENTION OF PERSONAL DATA
We will not keep your personal data for longer than necessary for the purposes for which the personal data is processed. The length of time we retain personal data depends on the purpose for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
9. DATA PROTECTION RIGHTS
Under data protection law, you have rights including:
Your right of access - You have the right to ask us for copies of your personal information.
Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.
Your right to object to processing - You have the right to object to the processing of your personal information in certain circumstances.
Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
The circumstances in which a data subject may take any of the above actions are set out in the UK General Data Protection Regulation. A data subject has the right to withdraw consent to process personal data where the Manager has relied on consent to process at any time. Please contact us using the below contact information if you wish to make a request based on your rights.
If you have any concerns about our use of your personal data you can make a complaint to us using the below contact information.
You can also complain to the ICO if you are unhappy with how have used your data. The ICO’s address:
Information Commissioner’s Office
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
10. HOW TO CONTACT US
If you have any questions about our use of your personal data, please contact the Manager:
11. CHANGES TO THIS NOTICE
We may update this Privacy Notice from time to time to reflect changes to our usage of personal data.