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inProp Capital Website Privacy Policy
This Privacy Notice (Notice) explains how inProp Capital LLP (inProp, we, our, us) processes the personal data of recipients of articles of interest and information from us (you, your) and your rights in relation to the personal data we hold.
inProp is the data controller of your personal data and is subject to the Data Protection Act 1998 (DPA) and, once in force, EU General Data Protection Regulation 2016/679 (GDPR).
inProp is registered as a data controller with the UK Information Commissioner's Office. This Notice was updated on 28th of October 2020 and supersedes any previous privacy notice or similar terms provided by, or on behalf of, inProp.
If you have any questions about your rights or how your personal data is used by inProp, you should contact the Data Protection Representative using the details below:
· Post – Paul Ogden
84 Aberdeen Park, London N5 2BE, United Kingdom
· Email - info@inpropcapital.com
· Telephone - +44 (0) 207 226 7571
How your personal data is collected
We collect your personal data in the following ways:
· From meetings, correspondence or other communications you have with us;
· From the website (www.inpropcapital.com);
· When you are introduced by a third party (such as a broker/dealer).
The categories of personal data collected
The following categories of personal data about you are collected by us:
· Name, and contact information (such as residential address, email address and telephone number);
· Information about your background including occupation, educational information and interests.
The basis for processing your personal data, how that data is used and whom it is shared with
1. Legitimate Interests
We may process your personal data because it is necessary for our legitimate interests. Our "legitimate interests" include our commercial interests in operating our business in a client-focused, efficient and sustainable manner, in accordance with all applicable legal and regulatory requirements:
· In this respect, personal data will be used by us for marketing purposes. Please see the separate section on Marketing below.
· In this respect, your personal data may be shared with the following:
o Our advisers (such as lawyers or accountants) where it is necessary to obtain their advice or assistance;
o Third parties who assist us with the services listed above (such as IT providers).
2. Legal Obligations
Your personal data will also be processed by us for compliance with our legal obligations.
· In this respect, your personal data will be used to meet compliance and regulatory obligations, such as:
o To meet our other compliance and regulatory obligations including in order to comply with any requirement of any applicable statute, regulation, regulatory rule and good practice, whether originating from the UK or elsewhere;
· In this respect, your personal data will be shared with the following:
o Our advisers (such as lawyers or accountants) where it is necessary to obtain their advice or assistance;
o Relevant regulators or law enforcement agencies;
Marketing
We will send you information about articles, information and data which relates to our core activities.
If you object to receiving marketing from us at any time, you should contact us using the details below:
· Post – Paul Ogden
84 Aberdeen Park, London N5 2BE, United Kingdom
· Email - info@inpropcapital.com
· Telephone - +44 (0) 207 226 7571
International transfers of data
When sharing your personal data with third parties as set out in this Notice, some of those third parties may be located outside the European Economic Area (EEA). In these circumstances, your personal data will only be transferred on one of the following bases:
· The transfer is to a recipient that has entered into European Commission standard contractual clauses with us;
· The transfer is subject to an Adequacy Decision made by the European Commission; or
· You have explicitly consented to the transfer.
You can obtain more details of the protection given to your personal data when it is transferred outside the EEA (including a copy of any standard contractual clauses which inProp has entered into with recipients of your personal information) by contacting the Data Protection Representative using the details set out above.
Retention of your data
We will retain your personal data for a period of seven years following the date on which you cease to be interested in the articles that we share, unless that personal data is required to be retained for a longer period by reference to an applicable law or regulation.
However, where there is a relationship between you and us after that time, we will retain such of your personal data as is necessary, and for such reasonable additional period, in order to maintain that relationship.
Your rights
You have the following rights:
· To obtain access to, and copies of, the personal data we hold about you;
· To require that we cease processing your personal data if the processing is causing you damage or distress;
· To require us not to send you marketing communications;
· To require us to erase your personal data;
· To require us to restrict our data processing activities in relation to your personal data;
· To receive from us the personal data we hold about you, which you have provided to us, in a reasonable format specified by you, including for the purpose of transmitting that personal data to another data controller; and
· To require us to correct the personal data we hold about you if it is incorrect.
Please note that the above rights are not absolute, and requests may be refused where exceptions apply.
If you are not satisfied with how your personal data is used by us you can make a complaint to the Information Commissioner (www.ico.org.uk).
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