Privacy Policy

Effective Date: 25 May 2018

Background

We are a Data Controller for the purposes of the EU Regulation 2016/679 (“GDPR”) and this means that we are responsible for, and control the processing of, your Personal Data.

We understand that your privacy is important to you and that you care how your Personal Data is used and shared.  We respect and value your privacy and will only collect and use Personal Data in ways that are described here, and in manner that is consistent with our obligations and your rights under the law.

“Personal Data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data.  This definition will incorporate, where applicable, the definitions provided in the GDPR. For more information please visit www.ico.org.uk.

Information about us

We are PENATRADA LIMITED (registered number 08172868 and VAT number 271086704), with our registered office at 22a St James’s Square, London, SW1Y 4JH, UK (“we/us/our”).

We own and operate www.penatrada.co.uk and www.penatrada.com (the “Website”).

What does this Policy Cover

This policy describes our privacy policy (the “Privacy Policy”) and explains how, when and why we collect your Personal Data in the course of our business and relationship.  Specifically, this Privacy Policy:

  • Sets out the types of Personal Data that we collect about you;
  • Explains how and why we collect and use your Personal Data;
  • Explains how long we keep your Personal Data for;
  • Explains when, why and with whom we will share your Personal Data;
  • Explains the different rights and choices you have when it comes to your Personal Data; and
  • Explains how we may contact you and how you can contact us.

Please read this Privacy Policy carefully and ensure that you understand it.  Your acceptance of the Privacy Policy is deemed to occur upon your receipt of this Privacy Policy or first use of the Website. If you do not accept and agree with this Privacy Policy, please immediately contact us and stop using the Website.

How We Collect Your Data

We collect your Personal Data in a number of ways, for example:

  • From information you provide to us when you meet us;
  • From information about you provided to us by your company, agents, advisors, intermediaries or representatives;
  • When you communicate with us in writing, by telephone, Website registration or enquiry, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
  • When you complete (or a third party complete on your behalf) a form that is provided to us;
  • From publicly available sources or from third parties, most commonly where we are required to conduct background checks about you; and
  • From use of cookies via the Website (please see “Our Use of Website Cookies” below for more information).

What Data Do We collect

Depending upon our relationship, we may collect some or all of the following categories of Personal Data about you:

  • Your full name including prefix, title and suffix;
  • Your contact information such as your home or business address, email address and telephone number;
  • Your biographical information which may confirm your identity including your date of birth, your passport number or national identity card details and/or your nationality;
  • Information about your employment, education, personal circumstances, and interests, where relevant;
  • Your bank account details;
  • Information to assess whether you may represent a politically exposed person or money laundering risk; and
  • Technical information such as IP address and other information relating to your visits to the Website and electronic communications with us (for example via email or through other digital mediums).

How We Use and share Your Data

Our use of your Personal Data will always have a lawful basis, either because it is necessary for our performance of a contract with you, because you have consented to our use of your Personal Data, or because it is in our legitimate interests.

Performance of a contract

We process your Personal Data because it is necessary for the performance of a contract, to which you are a party to or have an interest in, or in order to take steps at your request prior to entering into a contract with you.

In this respect, we use your personal data for the following:

  • To provide you with the services as set out in, and to meet our obligations under, the contract with you or as otherwise agreed with you from time to time;
  • To deal with any queries or feedback you may have; and
  • For any other purpose for which you provide us with your Personal Data.

In this respect, we may share your data with or transfer it to some or all of the following:

  • Your agents, advisors and other intermediaries who you tell us about;
  • Third parties (such as our contractors and intermediaries) whom we engage to assist in delivering the introduction services to you;
  • Third parties who we introduce or intent to introduce to you;
  • Our advisors where it is necessary for us to obtain their advice or assistance, including lawyers, accountants, auditors and IT advisors; and
  • Our data storage providers.

Legitimate interests

We also process your Personal Data because it is necessary for our legitimate interests, or sometimes where it is necessary for the legitimate interests of another person.

In this respect, we use your Personal Data for the following:

  • For marketing to you. In this respect, please see “Do We Use Data For Marketing” below;
  • For the administration and management of our business, including recovering fee or money you owe to us, and archiving or statistical analysis;
  • Seeking advice on our rights and obligations;
  • Replying to emails and responding to telephone calls from you;
  • To deal with any queries, feedback or complaints you may have;
  • Training our staff (including contractors) or monitoring their performance;
  • Providing and managing your access to the Website and your account to access and use certain areas and features of the Website;
  • Personalising and tailoring your experience on the Website;
  • Analysing your use of the Website (and gathering feedback) to enable us to continually improve the Website and your user experience; and
  • Any other purpose for which you provide us with your Personal Data.

In this respect, we may share your data with or transfer it to some or all of the following:

  • Our advisors or agents where it is necessary for us to obtain advice or assistance; and
  • With third parties and their advisors where those third parties are acquiring, or considering acquiring, all or part of our business.

Legal obligations

We may also process your Personal Data for our compliance with legal obligations, a court order or government authority, and where we are involved in legal proceedings.

In this respect, we use your Personal Data for the following:

  • To meet our compliance and any applicable regulatory obligations, such as compliance with anti-money laundering laws; and
  • As required by tax authorities or any competent court or legal authority.

In this respect, we will share your data with or transfer it to some or all of the following:

  • Our advisors where it is necessary for us to obtain their advice or assistance;
  • Our accountant or auditor where it is necessary as part of their auditing functions;
  • With third parties who assist us in conducting background checks; and
  • With relevant regulators or law enforcement agencies where we are required to do so.

How and Where Do We Store Your Data

All Personal Data is processed and stored securely in the UK or through third party data processors (such as cloud data storage service providers) within the European Union countries.

How long do we keep your data

Personal Data are stored for no longer than is necessary in light of the reason(s) for which it was first collected.  We will comply with our obligations and safeguard your rights under GDPR at all times. In particular:

  • Where we have collected your Personal Data as required by anti-money laundering legislation, including for identification, screening and reporting, we will retain that Personal Data for between five and seven years after the termination of our relationship, unless we are required to retain this information by another law or for the purposes of court proceedings; or
  • Otherwise, we will in most cases retain your Personal Data for a period of seven years after the termination of our contractual or other relationship with you in case any claims arise out of the provision of our services to you.

Do We Use data for Marketing

We may use your data for marketing purposes that include contacting you by email, telephone, post or other digital channels with information on our services that may be of interest.  This may be in the form of email alerts, newsletters and invitations of events or functions which we believe might be of interest to you in order to update you with information that we believe may be relevant to you.

We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR. Please contact us if you object to receiving marketing from us at any time.

Our Use of Website Cookies

We may use both “Session” Cookies and “Persistent” Cookies on the Website. We use the Session Cookies to keep track of you whilst you navigate the Website and we use the Persistent Cookies to enable the Website to recognise you when you visit. Session Cookies will be deleted from your computer when you close your browser. Persistent Cookies will remain stored on your computer until deleted, or until they reach a specified expiry date.

We also use Google Analytics to analyse the use of the Website. Google Analytics generates statistical and other information about website use by means of Cookies, which are stored on users’ computers. The information generated relating to the Website is used to create reports about the use of the Website. Google will store this information and Google’s privacy policy is available at http://www.google.com/privacypolicy.html.

We also publish Google Adsense interest-based advertisements on the Website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour across the web using Cookies. You can view, delete or add interest categories associated with your browser using Google’s Ads Preference Manager, available at http://www.google.com/ads/preferences/. You can opt-out of the Adsense partner network Cookie at http://www.google.com/privacy_ads.html. However, this opt-out mechanism uses a Cookie, and if you clear the Cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you should use the Google browser plug-in available at http://www.google.com/ads/preferences/plugin.

Most browsers allow you to reject all Cookies, whilst some browsers allow you to reject just third party Cookies. Blocking all Cookies will, however, have a negative impact upon the usability of many websites, including the Website.

“Cookie” mean a small text file placed on your computer or device by the Website when you visit certain parts of the Website and when you use certain features of the Website.

All Cookies used by and on the Website are used in accordance with the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Your rights

You have the following rights under GDPR, which this Privacy Policy and our use of Personal Data have been designed to uphold:

  • Information: you have the right to be provided with clear, transparent and easily understandable information relating to our collection and use of Personal Data;
  • Access: you have the right to access the Personal Data we hold about you;
  • Rectification: you have the right to require us to correct Personal Data we hold about you if it is incorrect or incomplete;
  • Withdrawal: you have the right to withdraw your consent to our processing your Personal Data at any time;
  • Objection: you have the right to object to us using your Personal Data for any purposes;
  • Erasure: you have the right to be forgotten and require us to erase Personal Data we hold about you;
  • Restriction: you have the right to require us to restrict or prevent the processing of your Personal Data;
  • Portability: you have the right to obtain a copy of your Personal Data we hold in a commonly used electronic format, so it can be transferred or re-use with a third party; and
  • Automated Decisions: you have rights with respect to automated decision making and profiling where electronic system uses Personal Data to make decisions without human intervention. In this respect, we do not carry out any automated decision-making.

Please note that the above rights may not absolute, and we may be entitled to refuse requests where exceptions apply. You can find out more about your rights at www.ico.org.uk.

If you have any questions about how we use your Personal Data, or you have any cause for complaint about our use of your Personal Data or wish to exercise any of your rights, please contact our Privacy and Data Compliance Officer using the contact details provided in this Privacy Policy below. If we are unable to help you or you are not satisfied with how we are processing your Personal Data, you also have the right to make a complaint to the Information Commissioner’s Office (ICO).

How can you access your data

You have the right to ask for a copy of any of your Personal Data held by us (and where such data is held).  We will provide any and all information in response to your reasonable request free of charge.  Please contact our Privacy and Data Compliance Officer for more details.

Contacting Us

Our Privacy and Data Compliance Officer is Paul Willson and can be contacted by:

  • Email at paul.willson@penatrada.co.uk;
  • Telephone on +44 20 3102 9470; or
  • Post at Data Protection, Penatrada Limited, 22a St James’s Square, London, SW1Y 4JH, UK.

Please contact us if you have any questions about this Privacy Policy. We ask you to ensure that your query is clear, particularly if it is a request for information about the data we hold about you.

Changes to our Privacy Policy

This Privacy Policy supersedes any previous Privacy Policy or equivalent which you may have been provided with or seen prior to the Effective Date stated above.

We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on the Website and you will be deemed to have accepted the terms of the updated Privacy Policy on your first use of the Website following the alterations or receipt of a copy of any updated Privacy Policy. We recommend that you check the Website regularly to keep-up-to-date on our Privacy Policy.