Hadrian’s Wall Capital Ltd (the “Firm”) is committed to protecting and respecting your privacy. This Privacy Notice sets out how your personal information is collected, processed and disclosed by the Firm, including any affiliates listed in the “Our Data Controllers and how to Contact us” section below (hereinafter also collectively referred to as “us”, “our” or “we”).
We take privacy and security of your information seriously and will only use such personal information as set out in this Privacy Notice.
The Firm and its affiliates are defined as a data controller under the General Data Protection Regulation (“GDPR”) and Data Protection Act 1998. This Privacy Notice covers personal information relating to you that we may collect through any medium, including specifically in relation to the investment services we provide to you, via our partners and service providers, or through our website. This Privacy Notice describes how you can access and make certain choices about how we use your personal information.
Your personal information that we may collect
Personal data, or personal information, means any information about a living individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect and process data with respect to persons connected with the advisory services we provide. As well as collecting personal data from our clients, we may also process personal data about relevant persons connected with the advisory services, for example intermediaries introducing business to us, investors in our funds, co-investors, directors and shareholders of investee company portfolios, etc.
We may collect this information from a number of sources, including directly from you, via our affiliates, delegates, partners, service providers, professional advisors, third-party entities with whom we undertake due diligence checks upon you or where your personal information is public information by your own actions. In doing so, we will ensure that the information we collect is proportionate to our stated purposes.
Where relevant, we may collect and process personal information related to persons related to you. In circumstances where you provide us with personal information in relation to persons related to you, it is your responsibility to ensure you have permission from that third-party to share with us their information and you remain responsible for ensuring that the third-party understands how their information is being used.
Individuals connected with our advisory services
We may collect and process your: personal details, including your name, address, email and telephone/fax numbers, date of birth, nationality; employment details, including your employers name, your position or title and your corporate contact details; information on your financial circumstances, including your profession, income, assets and liabilities, as well as special category and/or criminal data.
Individuals connected with our partners and service providers
We may collect and process your: contact information, including your name, address, position, email and telephone/fax numbers; financial details, including relevant details for invoicing and billing; and ‘know your client’ (“KYC”) documentation, if and where required under relevant Anti-Money Laundering or Counter Terrorism Financing (“AML/CTF”) legislation.
Individuals connected with our website
We may collect and process your: personal details, including your name and email, including any personal details you enter in the ‘Contact Us’ message area; and technical information, including your IP address, browser information, time zone settings and location, operating system and platform and other technology on the devices you use to access the website and details relating to your visit behavior on our website. Further details are provided in our “Cookie Notice” to be found in the footer of our website pages.
People signing up to RNS e-mail alerts on our website are given the option to share or not to share their registration information with us.
Our website is intended for professional investors only and not intended for children and we do not knowingly collect data relating to children.
Our lawful grounds and purpose for holding your personal information
Lawful grounds for processing:
We are entitled to hold and process your personal data on the following lawful grounds:
- the processing is necessary for our legitimate interests, provided that your interests and fundamental rights do not override those interests;
- where the applicant is a natural person, the processing is necessary to comply with our respective contractual duties to you under the terms of your contract with us and all supplemental agreements thereto;
- to comply with our legal and regulatory obligations;
- to perform due diligence checks, where we have obtained your consent; and
- (on rare occasions) where it is needed in the public interest.
Some of the grounds for processing described above will overlap and there may be several grounds which justify our use of your personal data.
Inaccurate or Amended Information
Please let us know if any of your personal data (including correspondence details) changes as soon as possible as it may impact the accuracy of the information we are holding on you and possible detriment to the delivery of any services provided.
Purposes of processing
We may process your personal data for the purposes set out below.
- conducting credit reference checks;
- communicating with you as necessary in connection with your affairs and generally in connection with your arrangements with us;
- operating our IT systems, software and business applications;
- supporting our IT and business applications support teams, accounting, legal, reporting, internal audit and risk management, administrative, registrar, document storage, record keeping and other related functions, including but not limited to processing personal data in connection with services provided;
- monitoring and recording telephone and electronic communications and transactions:
- for quality, business analysis, training and related purposes in order to improve service delivery;
- for investigation and fraud prevention purposes, for crime detection, prevention, investigation and prosecution of any unlawful act (or omission to act); and
- to enforce or defend our respective rights, or through third parties to whom we each may delegate such responsibilities or rights in order to comply with a legal or regulatory obligation imposed on each of us;
- detecting and preventing crime such as fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanction on an ongoing basis;
- facilitating our internal administration and retaining your personal data as part of our Regulatory Assessments or future services entered into by you;
- liaising with or reporting to any regulatory authority (including tax authorities) with whom we are either required to cooperate or report to, or with whom we decide or deem appropriate to cooperate, in relation to our services, and which has jurisdiction over us;
- communicating with our professional advisers for the purposes of obtaining professional advice;
- conducting business analytics and diagnostics;
Disclosure of your personal information
We may disclose your personal information with the following category of recipients, and based upon the lawful purposes set-out above:
- Our affiliates, including where relevant third-party investment funds that we advise.
- Our partners and service providers, including service providers appointed by the third-party investment funds that we advise;
- Any law enforcement, court, regulator or other government authority in order for us to comply with a legal obligation laid down by UK or EU law. This includes the provision of information relating to any affiliate of the Firm.
- A prospective buyer of our business, including where we intend to sell part of our business or merge with another third-party.
We will not sell or disclose your information to a third party for marketing purposes.
How and where we store your personal information
We store your physically held personal information in our UK offices. Whereas we store your electronically held personal information on servers located in the UK or in an EU designated territory subject to the same GDPR and backed-up in the UK or in an EU designated territory subject to the same GDPR.
Whilst we have taken every reasonable care to ensure the implementation of appropriate technical and security measures, we cannot guarantee the security of your personal data over the internet, via e-mail or via our websites nor do we accept, to the fullest extent permitted by law, any liability for any errors in data transmission, machine, software or operating error or any other cause.
We may transfer your personal information to our affiliates, partners or service providers that are based outside of the European Economic Area (EEA). In such circumstances, we will ensure that your personal information is adequately protected as though it were in the EEA.
Your rights as a Data subject
Unless subject to an exemption under the GDPR relating to a particular lawful basis used, you may have the following rights with respect to your personal data:
- to request a copy of your personal data which we hold about you;
- to request that we correct any of your personal data if it is found to be inaccurate or out of date;
- to request your personal data to be erased where it is no longer necessary for us to retain such data;
- to request that we provide you with your personal data to transmit the data directly to another data controller (known as the right to data portability);
- where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- the right to object to processing your personal data
- to object to the processing of your personal data with regards to Direct Marketing;
- to lodge a complaint with the Information Commissioner’s Office (ICO).
Further details of your rights can be found at the ICO website, however, please note that your rights are subject to our overarching legal responsibilities: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
If you wish to exercise any of these rights, please contact the relevant data controller (listed below).
- Where we have obtained your written consent to allow us to collect and process your personal data for a specific purpose, you have the right to withdraw your consent at any time. To withdraw your consent, please contact the relevant data controller (listed below)
How long we retain your personal information
Your personal data will be retained for the longest of the following periods:
- by us and/or any authorised third parties to carry out the Purposes for which the data was collected or as long as is set out in any relevant agreement you enter into with us;
- in order to establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations;
- any retention period that is required by data protection laws and any applicable laws or regulatory requirements.
We endeavour and require all third parties with access to your personal data, to store such data securely on computer systems in accordance with accepted market standards.
Our Data Controllers and how to contact us
Questions or individual data requests relating to this Privacy Notice should be addressed to the relevant data controller. For the purpose of the data protection legislation, the relevant data controllers are:
|Data Controller||Responsible for|
|Hadrian’s Wall Capital Limited
Company No: 07203454
48 Gresham Street
|All investment advisory activities and business administration activities related to our regulated services. The adviser to Hadrian’s Wall Secured Investments Limited.|
|Hadrian’s Wall Capital AG
Bahnhofstrasse 3, 8808 Pfaffikon,
|the Firm as parent of the Firm.|
|HWSIL Finance Co Limited
Company No: 10144063
Mermaid House, 2 Puddle Dock
London, EC4V 3DB
|Provision of finance, the lender, a wholly owned subsidiary of Hadrian’s Wall Secured Investments Limited.|
|HWSIL Asset Co Limited
Company No: 10889169
Mermaid House, 2 Puddle Dock
London, EC4V 3DB
|Provision of capital, the asset owner, a wholly owned subsidiary of Hadrian’s Wall Secured Investments Limited.|
|Upper Thames Services Limited
Company No: 10638136
48 Gresham Street
|Provision of loan administration and servicing by the Firm|
Our responsibilities when we make changes to our Privacy Notice
This Privacy Notice is dated 25 May 2018.
We may make changes to our Privacy Notice at any time and may do so without expressly notifying you of these changes. However, should the lawful purpose for processing your personal information changes then we shall expressly notify you.