Welcome to Bedford Row Capital plc. We understand that privacy online is important to users of our website, especially when conducting business. This statement governs our privacy policies with respect to those users of the site ("visitors") who visit without transacting business and, visitors who register to transact business on the site and make use of the various services offered by Bedford Row Capital plc.
For the purpose of the Data Protection Act 1998 or any replacement legislation including the EU General Data Protection Regulation (together, the "Data Protection Legislation"), the data controller of your information is Bedford Row Capital plc (BRC), 1 Bedford Row, London WC1R 4BZ, under registration number 10010194.
By accessing any part of this Site, or otherwise using our services, you acknowledge that we may collect, use and transfer your personal information as described in this policy. If you do not agree with the terms of this policy, please do not continue to access this Site or use our services. If we ask for your consent to a particular use of your information on this Site or otherwise and you give that consent, that use will also be covered by this policy. We recognise the need to treat any information which you do provide in an appropriate and lawful manner.
What We Collect
BRC collects and keeps information about:
· how to reach you (such as name, title, firm, mailing and e-mail address, phone and fax number);
· how to bill you or register collateral charge over your assets (such as bank information and billing address); and
· information about which specific markets, functional areas, and types of information are pertinent to you.
We may also automatically collect technical information when you visit or otherwise use our Site, such as your IP address, and information about your visit, such as the pages that you viewed.
· Subject to your rights, we may use the above information to:
· perform any contract which we may have with you;
· help us send you information that is useful to you;
· avoid bothering you with information that isn't useful to you;
· comply with our legal obligations; or
· protect our legitimate business interests e.g. to analyse the use of the Site or our services in order to continually improve them.
When We Collect It
We may collect your information from multiple sources. We collect information through our Site when you fill out an online form or, respond to one of our e-mail notices or, otherwise communicate with us.
Further examples of ways in which we may collect your information include:
· when you participate in our due diligence exercises;
· when you attend one of our meetings;
· when you provide us with your business card;
· when you write to or otherwise communicate with us; or
· when you provide us with information orally.
What We Receive From Other People
We occasionally work closely with third parties who may collect personal information from you and pass it on to us. Our staff may also give us emergency contact information as part of our emergency scenario planning and may give us details of their next of kin or dependants in relation to their employee benefits arrangements. Where this is the case the third party is responsible for obtaining the relevant consents from you to ensure you are happy with the ways in which your personal data will be used.
What We Do With It
· Data gathered on BRC forms:
When you submit an online form through our Site, we use the data to process your enquiry. Your email address is used where you have consented or where we are otherwise entitled to do so, to store the data provided so that it's easier for you to register for future events and to send you our newsletter or other communications.
· When you ask for a password:
If you're asked for some information when you apply for a password to secure pages, it's used to generate a password and communicate password and other pertinent information relating to your account to you.
· User Type:
The information you provide us with may also be used to help us identify the type of user you are, whether you are a Sponsor, Distributor, Broker, Sales Manager or representative of a High Net Worth individual or, any other wholesale investor.
· Third Parties:
You should be aware that, where you have consented, your business contact information may also be provided to third parties. In addition, and where applicable, your payment details may be provided to our third party services providers (such as our payment processors or Registrar) so that we can process your order(s).
· Compliance with Laws and Regulations:
We, or our third party service providers, may disclose information to comply with applicable laws and regulations, such as to respond to a subpoena or similar legal process, and to otherwise cooperate with law enforcement or regulatory authorities.
· Business analysis:
Subject to your rights and in accordance with standard business practices, BRC and/or its third party services providers may use your data to monitor or analyse its business practices.
· Sending marketing communications:
Where you have consented, or where we are otherwise entitled to do so, your contact information may be used to send you information about BRC's services that may be of interest to you by email. You may opt out of receiving marketing communications from us or our associated third parties by:
(a) contacting us at email@example.com or
(b) following the instructions in the relevant marketing communication.
· In the event of a sale, merger or financing:
In accordance with standard business practices, if BRC or any of its third party suppliers to whom your data is sent enters into a joint venture with, purchases or is sold to or merges with another business entity, or obtains finance, your data may be disclosed or transferred to the relevant target company, new business partner, or finance provider or their advisers.
Data Accuracy and Retention
We use reasonable endeavours to ensure that all personal information we hold about you is accurate and up to date. Information which is incorrect, or misleading is inaccurate, and steps will therefore be taken to check the accuracy of any personal information. Inaccurate or outdated information will be destroyed. Please assist us in keeping your information as accurate as possible by updating us in the event that anything changes.
We will usually inform you (before collecting your information) if we intend to use your information for marketing or research purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time, raise any queries or complaints in relation to how we use your information by contacting us at firstname.lastname@example.org. Should you wish to take any complaints or queries further, you have the right to contact the Information Commissioner's Office regarding such issues.
Accessing and updating your information
You have the right to see the information we hold about you and to ask us to:
· make any changes to ensure that any information we hold about you is accurate and up to date;
· erase or stop processing any information we hold about you where there is no longer a legal ground for us to hold it; or
· in some cases, transfer any information we hold about you to a specified third party.
If you wish to do this, please contact us using the contact details set out below.
Security, data transfers outside of the EEA and data retention
We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage. We will only keep your information for as long as we reasonably require and, in any event, only for as long as Data Protection Legislation allows.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") or the United Kingdom ("UK"). It may also be processed by staff operating outside the EEA or the UK who work for us or third parties engaged in, among other things, the provision of support services to us. By submitting your personal data, you acknowledge this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy and the Data Protection Legislation. This means that we will only transfer your information to third parties that:
· are in countries that have been confirmed by the European Commission to provide adequate protection to personal information; or
· have agreed to provide all protections to your personal information as set out in the Data Protection Legislation.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
The registration processes on our website may involve you giving a password and account designation. You are responsible for maintaining the confidentiality of the password and account and are fully responsible for all activities that occur under your password or account. You agree to:
· immediately notify BRC of any unauthorised use of your password or account and any other breach of security, and
· ensure that you exit from your account at the end of each session.
BRC cannot and will not be liable for any loss or damage arising from your failure to comply with this obligation.
Changes to This Policy
Last reviewed July 2020