Last Updated December 2019
Thank you for visiting https://www.albourne.com/. We are committed to protecting and respecting your privacy.
In respect of your personal data, Albourne Partners Limited, 16 Palace Street, London, SW1E 5JD Tel +44 (0)207 346 7000, is the data controller where required.
Please read the following carefully to understand what personal data we collect, how that personal data is used and the ways it can be shared by us and you. IF YOU DO NOT ACCEPT AND AGREE WITH THIS PRIVACY STATEMENT THEN YOU MUST NOT ACCESS ANY ALBOURNE WEBSITE.
Albourne Websites (as defined below) may, from time to time, contain links to and from the websites of third parties and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
In accordance with this Privacy Statement, Albourne may collect, use and process your personal data (including your special category data and data relating to criminal convictions and offences), together with other information, for the uses set out below. Where applicable, for the purposes of this Privacy Statement “processing”, “transferring”, “personal data”, “special category data” and “data relating to criminal convictions and offences” shall be interpreted in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”).
Where required, we will collect, store, use and disclose personal data in accordance with all applicable laws relating to the protection of Personal Data, including the GDPR and the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation together with any and all other applicable privacy laws and standards in those jurisdictions in which Albourne operates (together “Applicable Data Laws”).
Collection of Personal Information
Personal information may be collected from you in the course of your use of any website or application owned or operated by us (each an “Albourne Website”), and/or in any communication between you and Albourne personnel. This information includes the following categories and types of personal data:
If you are an Albourne client, prospective Albourne client or a fund manager we may also collect information about you from company and trade registers, and other publicly available sources. We may also request information on you from third parties. We may then combine this information with any information you give to us and other information we collect about you. We will use this information and the combined information for the purposes set out below (depending on the types of information we receive).
If you are an individual associated with an investment management company or a fund, please also see the “Information for Fund Managers” located at https://www.albourne.com/moatspace/managerinformation for a more detailed privacy notice and information on the categories of personal information Albourne collects about you and your firm’s executives and other key employees in connection with Albourne’s due diligence of investment vehicles and associated management companies.
Under GDPR, we process your personal data for the purposes as disclosed to you only:
Additionally, Albourne will process personal data fairly and in accordance with Applicable Data Laws. In particular, and to the extent required by Applicable Data Laws, Albourne will ensure that your personal data is:
Special category data and data relating to criminal convictions and offences
To the extent we have a business need to collect your special category data and data relating to criminal convictions and offences for the purposes set out below, and are permitted to do so by local laws, we may collect and use your special category data and data relating to criminal convictions and offences. If we do so, and are required by local laws, we will contact you to obtain your consent for this collection and use in advance. You may withdraw your consent at any time by sending a request to the Personal Data Protection Officer at firstname.lastname@example.org.
Uses of personal data
Albourne may use your personal data for any of the following purposes:
If you are located in the European Economic Area (“EEA”), you have a number of rights in relation to how we process your personal data. These include:
You can exercise any of these rights any time by contacting our Group Personal Data Protection Officer at email@example.com.
If you are located outside of the EEA, you may have similar rights, which are also exercisable by contacting us.
We set cookies (first party cookies) on web pages. We also use Google Analytics (third party cookies) on https://www.albourne.com/ to optimise the Albourne Website and make it more relevant to your interests. Here is a link to the site "How Google uses data when you use our partners' sites or apps located at www.google.com/policies/privacy/partners/.
The cookies we use are of two kinds:
How do I control my cookie settings on my computer or device?
Please note that if you decide to disable or block cookies, parts of the Albourne Website may not function correctly or at all. Should you choose however to disable or block our cookies on your computer or other device you will need to do this through your browser. Click on the 'Help' menu on your browser to learn how to manage your cookie preferences. Alternatively, you can visit www.aboutcookies.org or www.youronlinechoices.eu for comprehensive information on how to manage cookies.
If you are a potential Albourne client (e.g., an investor) Albourne may contact you by mail, telephone, fax, e-mail or other electronic messaging service with offers of Albourne’s services, materials, news, training or events that may be of interest to you. If you do not wish to receive such information from Albourne, or you have changed your mind, please email your wishes to firstname.lastname@example.org. If you register with an Albourne Website, options to opt-in to such communications are offered to you there. By opting-in and providing Albourne with your contact details, you consent to being contacted by those means for those purposes. If you do not wish to receive such information from Albourne, or you have changed your mind, and wish to change your privacy settings, please visit https://village.albourne.com/castle/profile, if you are a Castle User or https://village.albourne.com/village/login for Village Users or https://www.albourne.com/albourne/freeparking/profile, if you are an Investor Portal User. Albourne will never pass your contact details on to a third party for direct marketing purposes.
Albourne operates as a global business and may have a business need to transfer your personal data to countries outside the EEA or your ordinary place of residence (“Your Home Country”) which do not provide the same level of data protection as the EEA or Your Home Country. This includes transfers the object of which is (i) to enable information to be accessed by Albourne personnel located outside the EEA or Your Home Country who need to know the information in order to do their jobs; and/or (ii) to enable information to be accessed by Albourne clients located outside the EEA or Your Home Country, where applicable. We have put terms in place to ensure that your information is adequately protected and your privacy respected in the case of such a transfer.
Please note that, when you give us information about another individual for business purposes, including their personal data (which may include special category data and data relating to criminal convictions and offences), you warrant and represent that the other individual has (i) given permission for you to do so, (ii) consented to our processing of his or her personal data for the purposes set out in this Privacy Statement, (iii) consented to the transfer of his or her personal data abroad in accordance with this Privacy Statement, and (iv) consented to your receiving, on his or her behalf, any data protection notices from Albourne.
Monitoring of communications
To ensure that Albourne follows your instructions correctly and to improve our service through training of its staff, Albourne may monitor any communication between you and Albourne.
How we protect your Personal data
People We educate our employees to treat personal information and personal data with care. They are required to limit their access to information that they need to perform their jobs, such as to conduct our business, operate the Albourne Website, and in the case of a Albourne client, service your account or help you pursue your financial objectives. All our employees are required by contract and Albourne’s policies to keep all personal information secret, confidential and secure, and must take particular care not to disclose it to any other person (whether inside or outside Albourne) unless there is a legitimate Albourne business need and they are authorised to do so.
Procedures In compliance with applicable laws and regulations, we maintain physical, electronic and procedural safeguards to protect your personal information. In addition, we have put in place Data Transfer Agreements (based on approved EEA model clauses) between those Albourne companies located in the EEA and those located outside the EEA to govern the transfer of data outside the EEA. These terms ensure that personal data and information is adequately protected within Albourne and that individuals’ privacy is respected.
Security We take such security measures as we deem appropriate and proportionate to keep all information (including personal data) confidential and secure against unlawful processing and to prevent loss, destruction or damage.
Amendments and queries
If your personal details change please amend them by editing your details within the Albourne Website, or contact email@example.com or contact your Client Account Manager.
If you have any questions about how Albourne uses your personal information, please email firstname.lastname@example.org. If you are an individual located in Singapore and have a query in relation to the Personal Data Protection Act in Singapore, please contact Debra Ng at +65 6536 9541.
Under local laws, you may be entitled to ask for a copy of your personal data. Please also address any such requests to email@example.com or any alternative method described below.
Should you have cause to complain about how we handle your personal data, please contact us in the first instance. We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to the applicable data protection authority in the country in which you are located. For EEA users, this is the UK Information Commissioner’s Office (ICO): https://ico.org.uk/concerns/ or https://ico.org.uk/global/contact-us/.
Any changes we make to this Privacy Statement will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Statement. If we intend to use, process, or disclose personal data for purposes materially different than those described in this Notice, we will inform you before proceeding with the use, processing, or disclosure.
Notice for California Residents
For United States residents in California, personal data or personal information has the meaning given in the California Consumer Privacy Act of 2018 (the “CCPA”).
We will collect, store, use and disclose personal data in accordance with the CCPA.
The CCPA may provide you with the following rights.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you. You will not receive discriminatory treatment by Albourne for the exercise of rights conferred to you by the CCPA.
To request access to or deletion of personal information:
o visit the websites referred to above
o call 1-888-687-7963
o email firstname.lastname@example.org
To opt out of sale of your information visit California Residents – Do Not Sell My Info at http://www.albourne.com/albourne/ccpa/optout.
Identity verification. CCPA requires us to verify the identity of the individual submitting the request before providing a substantive response to the request. We will verify your identity by asking you to provide at least two personal data points to see whether it matches the data points maintained by Albourne, which we have determined to be reliable for the purpose of verifying your identity. Depending on the sensitivity of the personal information at issue, we may require that you sign a declaration under penalty of perjury that you are a CA resident whose personal information is the subject of the request.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority if we decide to use an authorized agent.