This privacy policy (“Policy”) describes how Hanover Square Capital (UK) Ltd (“HSC”, “us”, “we” or “our”) collects, uses, discloses, and/or processes your personal data through the use of our website. HSC is the controller and is responsible for your personal data. HSC respects your privacy and is committed to protecting your personal data.

By using or accessing any part of our website, you hereby agree to be bound by the terms of this Policy. If you do not agree to be bound by this Policy, you should not access or use our website or disclose any personal data through our website.

This Policy is incorporated into and is subject to our Terms and Conditions of Use of the website, which is available here.

  1. Definitions

“CCTV” means Closed-circuit Television;

“personal data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data);

“personnel” means any individual engaged under a contract of service with HSC, a contract for service with HSC, permanent or temporary employees as well as interns engaged by HSC from time to time;

“potential personnel” means any individual who has submitted an application to be engaged by HSC as personnel; and

“you” means a natural person, whether living or deceased and “‘your” shall be construed accordingly.

  1. Personal data collected by HSC

Information that you provide to HSC

This includes information about you that you provide to us. Such information may include (by way of a non-exhaustive list) basic personal data (such as first name; family name; job title; company name; company email address; business phone number; business address; city; postcode; country).

Information that we collect or generate about you

This includes:

  • a file with your client records and contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you; and
  • details of site and marketing/communication preferences.

Information we obtain from other sources

This includes:

Cookies
When you visit our website, cookies are used to collect information about the services that you use, and how you use them. Cookies are essentially a small amount of data which is transferred to and sometimes updated on your computer or other devices by our web servers.

For more information on the cookies used by HSC please see our Cookie Policy.

Anonymised data

In addition to the categories of personal data described above, HSC will also process further anonymized information and data that is not processed by reference to a specific individual.

  1. How we use your personal data

Your personal data may be stored and processed by us in the following ways and for the following purposes:

Provision of services

  • managing our relationship with you which will include: (a) registering you as a new client and maintaining a directory of contacts; (b) notifying you about changes to our terms or privacy policy; (c) managing payments, fees and charges; (d) collecting and recovering money owed to us; and (e) organising meetings between you and HSC’s representatives;
  • conducting anti-money laundering checks, administering and maintaining records of services or advice we have provided;
  • administering and protecting our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • using data analytics to improve our website, products/services, marketing, customer relationships and experiences; and
  • sending you periodic updates about HSC’s business, events, presentations and opportunities, including by email and post; you can opt out of receiving updates at any time by contacting us using the details in section 9 below.

Personnel

  • administering, managing and/or terminating HSC’s relationship with personnel;
  • evaluating the performance of personnel;
  • undertaking staff training and quality assurance activities;
  • providing personnel with services, facilities and/or other benefits being offered or made available by HSC to such personnel as well as information about such services, facilities and benefits;
  • communicating 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, such as dealing with legal claims made against us and preventing fraud; and
  • where we need to comply with a legal or regulatory obligation.

Potential personnel

  • taking steps prior to entering into a contract with you (for example your employment contract, consultancy contract or partnership agreement);
  • 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;
  • conducting criminal and reference checks;
  • communicating with you; and
  • where we need to comply with a legal or regulatory obligation.

Individuals who are associated with HSC’s suppliers, vendors or professional advisers

  • if you are a supplier or vendor to HSC, or one of our professional advisers, we will collect, use and store limited amounts of personal information relating to you, including your name, job title, qualifications, employer or parent organisation and contact details; and
  • we will collect, use and store this personal information for the purposes of conducting anti-money laundering checks, administering and maintaining records of goods, services or advice we have received, and commissioning further services or procuring further goods.

Visitors to HSC’s office

  • we will collect contact information in line with our legitimate interests (security of the building); and
  • video images of you in the entry and exit areas from CCTV footage in line with our legitimate interests (security of the building, preventing, detecting and investigating fraud, misconduct, any unlawful action, omission or dispute, and whether or not there is any suspicion of the aforementioned).

Others

  • we will collect personal data for any other purposes in relation to which HSC has specifically obtained your consent.

Legal bases for using personal data

We will only collect, use, and share your personal data where we are satisfied that we have an appropriate legal basis to do so, such as:

  • where we have your consent;
  • 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; and
  • where we need to comply with a legal obligation.

If you would like to find out more about the legal bases on which we process personal data, please contact us using the details listed in section 9 below.

  1. Disclosures of your personal data

We may also share your personal data with third parties such as:

  • with other trusted businesses or persons for the purpose of processing personal data on our behalf for the above stated purposes. These will include any depositary, stock exchange, clearing or settlement system, counterparties, dealers, custodians and others where disclosure of your personal data is reasonably intended for the purpose of effecting, managing or reporting transactions or establishing a relationship with a view to such transactions;
  • with our business partners;
  • with third-party agents and contractors for the purposes of providing services to us (for example, HSC’s accountants, professional advisors, IT and communications providers, credit reference agencies and debt collectors);
  • analytics and search engine providers that assist us in the improvement and optimisation of our website;
  • with representatives, agents, custodians, intermediaries and/or other third-party product providers appointed by you (such as accountants, professional advisors, custody service providers and product providers);
  • to the extent required by law, for example if we are under a duty to disclose your personal data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend our legal rights;
  • if we sell our business or assets, in which case we may need to disclose your personal data to the prospective buyer for due diligence purposes;
  • if we are acquired by a third-party, in which case the personal data held by us about you will be disclosed to the third-party buyer; and
  • with Hanover Square Investments Pte. Ltd who is a connected company of HSC based in Singapore and provides services to HSC.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

  1. International transfers

We share your personal data with our connected company, Hanover Square Investments Pte. Ltd. This will involve transferring your data outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:

  • we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
  • where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.
  1. 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 on a need-to-know basis. 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.

  1. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

  1. Your legal rights

In all the above cases in which we collect, use or store your personal data, you may have the following rights below and, in most cases, you can exercise them free of charge.

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the data’s accuracy;
    • where our use of the data is unlawful but you do not want us to erase it;
    • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; and
    • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you make a request, we have one month to respond to you. You can exercise your rights by contacting us using the details listed in section 9 below.

  1. Contact us

If you want to contact us with specific queries or concerns in relation to this Policy, request to access and/or correct your personal data in our possession, or if you have any questions or complaints as to how your personal data is collected, used, disclosed and/or processed by us, please contact us at:

Full name of legal entity: Hanover Square Capital (UK) Ltd
Email address: http://www.hansq.com
Postal address: 4th Floor, 49 St James Street, London SW1A 1AH, UK
Telephone number: +44 (0)20 7930 4695

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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.