Waveney Capital Management Limited – Privacy Notice

 

This notice describes how Waveney Capital Management Limited (“Waveney”) uses personal data. It outlines Waveney’s data protection obligations and your data protection rights under the regime introduced by the EU General Data Protection (Regulation 2016/679, the "General Data Protection Regulation").

 

The GDPR applies to “personal data” meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier.

 

Waveney needs to use your personal data to provide its services to you. This notice outlines the following points about the processing of your personal data:

  • which data items are used, how they are used and who they are shared with;

  • why this is done and the lawful basis; and

  • your rights and Waveney’s obligations.

 

Why Waveney Needs To Process Personal Data

 

Your Data is collected to effectively and properly manage your relationship with us. Data is stored for specific purposes and only data that is relevant to that purpose will be stored. We will use the Data for several different purposes, including:

  1. to carry out obligations (such as but not limited to arranger services) arising from any agreements entered into between you and Waveney;

  2. to provide you with information, products or services that you request from us (including through our website) or which we feel may interest you; and

  3. to competent authorities (including tax authorities), courts and bodies as required by law or requested or to affiliates for internal investigations and reporting.

Data Collection

Waveney may collect data:

  1. when you or an agent of yours contacts Waveney in relation to business and services offered;

  2. when you complete documents or forms during the course of business with Waveney;

  3. from Service Providers and other third parties that assist us in conducting business;

  4. when you telephone Waveney; and

  5. when you use the Waveney website.

Types Of Data That Might Be Collected

 

During Waveney’s relationship with you Waveney will collect and process Data about you, including:

 

  1. information that individuals and entities provide when contacting us (including through using this website) such as their names, postal addresses, telephone numbers, identification documents and email addresses;

  2. corporate information;

  3. details of services provided to you; and

  4. where permitted or required by regulators or the law, special categories of personal information such as information relating to criminal convictions or offences.

Data Sharing

Waveney uses Service Providers to conduct aspects of its business, so information may be disclosed to them and their affiliates Data that you have provided in order to fulfil the purposes for which the Data is held. These Service Providers may disclose such Data to each other and to each other’s affiliates in order to achieve the same purposes.

 

Waveney and its Service Providers may also be required to disclose your Data to governmental agencies, self-regulatory organisations, industry associations and similar bodies in order to fulfil legal and regulatory requirements. In addition, the laws of certain countries and states give people involved in lawsuits and other legal proceedings the right under certain circumstances to obtain information from Waveney and its Service Providers, including your Data. Waveney and its Service Providers will comply with these laws to the extent required.

 

Waveney will not sell your Data to any third party. Wherever possible, Service Providers are required to enter into confidentiality agreements that prohibit them from selling or improperly using your Data.

Data Retention

Waveney will retain your personal information for a period of up to seven years following the point where the business relationship has ceased.

It may be necessary to retain your personal information beyond this period depending on additional legal/regulatory obligations. Thereafter, Waveney will refrain from collecting any further personal information on you and shall take appropriate steps to dispose of any records containing your personal information to the extent this is operationally feasible and proportionate.

Cookies

We do not collect data about our users other than if you contact Waveney using the 'Contact Us' form. This website does not place cookies on your computer and does not use any other means of data collection. From emails we may collect your name, your email address and any other information which you decide to supply.

Lawful Basis For Processing

Waveney assesses all personal data that is collected or stored to ensure that there is a legal basis for each type of data under GDPR. The majority of lawful basis for Waveney’s processing is to meet its obligations to the FCA (legal obligation basis) or to fulfil its obligations to clients under contract (contract basis).

Other lawful basis may be used where Waveney assesses this is necessary and appropriate.

Data Subject Rights

You have the following rights, in certain circumstances, in relation to your personal information:

  • Right to access your personal information (in an easily readable form);

  • Right to rectify your personal information;

  • Right to restrict the use of your personal information (in certain specific circumstances);

  • Right to request that your personal information is erased (in certain specific circumstances). Please note that the right for your data to be erased (the "right to be forgotten") that applies in some contexts under the General Data Protection Regulation is not likely to be applicable to most, if not all, of the personal information you provide to Waveney, given the specific nature of the purposes for which Waveney uses the data, as described above;

  • Right to object to processing of your personal information (in certain specific circumstances);

  • Right to data portability (in certain specific circumstances);

  • Right to withdraw consent (in certain specific circumstances); and

  • Right to receive information regarding any entities we disclose your data to.

Where Waveney or its Service Provider(s) requires your personal information to comply with AML or other legal requirements, failure to provide this information means Waveney will not be able to accept you as a client or investor.

 

Waveney shall notify you of any personal information breach affecting you that is likely to result in a high risk to your rights and freedoms.

Changes To This Notice

 

Waveney will need to update its privacy notice in response to regulatory requirements or changes to its business. The latest notice will always be available on the Waveney website (www.waveneycapital.com).

How To Contact Waveney

 

Under the GDPR, data subjects can make a complaint to the supervisory authority including the Member State in which they reside or work or the place of the alleged infringement.

 

If you have any questions or concerns about personal data or this privacy policy or you wish to make a complaint about how Waveney has processed your personal data, please contact Waveney by writing to info@waveneycapital.com or by post at the following address: Waveney Capital Management Limited, 10 Bruton Street, London, W1J 6PX

Waveney Capital Management Limited, 30th November 2018

Waveney Capital Management Limited (FCA reference number: 824483) is an appointed representative of Thornbridge Investment Management LLP (FCA reference number: 713859) which is authorised and regulated by the Financial Conduct Authority.

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