This notice explains what personal data (“information”) ProFin Partners Ltd (“Profin”, “we”) as a controller holds about you, how we collect it, and how we use and may share information about you. We are required to notify you of this information under data protection law. Please ensure that you read this notice (sometimes referred to as a “privacy notice”) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

We are committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified, then you can be assured that it will only be used in accordance with this privacy statement.

How we collect your information

We collect or obtain information about you:

-   When you provide it to us (e.g. by emailing us, contracting with us for services, meeting us in person, contacting us by phone or subscribing to our newsletters).
-   From a third party (e.g. clients or other businesses we work with who may recommend our services to you).
-   From publicly accessible sources (e.g. Companies House, business directories, media publications, social media, and websites).

What information we collect

We may collect the following information on you:

-   Name, date of birth and job title.
-   Contact information including your email address, phone number and location.

We do not collect any special categories of data, such as those relating to religion, ethnicity, health, or political opinion.

What we do with the information we gather

We gather and process your information for the below purposes:

-   Performance of a contract with you or to be able to provide you, at your request, with a contract for our services.
-   For compliance with legal obligations (e.g. MiFID 2 record keeping requirements).
-   Internal record keeping.
-   We may use the information to improve our products and services.

We may periodically send promotional emails about new products, ideas or other information which we think you may find interesting using the email address which you have provided.

-   From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.

According to data protection law, we will process your information only to the extent that at least one of the below applies:

-   When you consent to it.
-   When it is necessary for the performance of a contract.
-   When it is necessary for compliance with a legal obligation.
-   When it is in our (or a third party’s) legitimate interest and it does not override your interests or fundamental rights and freedoms.

Our legitimate interest includes:

-   Processing for direct marketing purposes.
-   To on-board you as a new client.
-   To meet our regulatory obligations to provide you with regular information about your investment.
-   To contact you about other services that you might be interested in.

Please note that we may use or disclose your information if we are required by law to do so or if we reasonably believe that use or disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

How we share your information

We use service providers to help us run our business and who process your information for us on our behalf, such as telephone, email, IT and accounting providers. All our service providers are based in the United Kingdom.

Your information will be shared with these service providers only where necessary to enable us to run our business and, as much as possible, on an anonymous basis. When your information has been anonymised by us, it will not be considered personal data anymore.

Security

In order to prevent unauthorised access/use/modification, loss and theft, we use suitable physical, electronic and managerial procedures to safeguard and secure your information. The information we collect from you is not transferred outside of the EEA.


Controlling your information

We will not sell, distribute or lease your information to third parties unless we have your permission or are required by law to do so. You have certain rights on the information we have collected or processed which you can exercise under certain circumstances. These rights are to:

-   request access to your Personal Data (known as a “data subject access request”) and request certain information in relation to its processing.
-   request rectification of your Personal Data.
-   request the erasure of your Personal Data (known as a “right to be forgotten”).
-   request the restriction of processing of your Personal Data.
-   object to the processing of your information.
-   request a transfer of your information.
-   to withdraw your consent.

If you fail to provide us with the information necessary for us to enter into a contract with you, or information we require by law, we may not be able to provide you with the services you requested and may have to cancel any services we provide you with.

Depending on the rights you wish to exercise, certain circumstances will apply. We have the obligation to erase your information on your request, where one of the following grounds applies, and only if our processing is not necessary for compliance with a legal obligation we are subject to:

-   The information is no longer necessary in relation to the purpose it was collected for.
-   You withdraw your consent and there is no other legal ground for us to process your information.
-   You object to us processing your information and there are no overriding legitimate interests for us to process.
-   Your information has been unlawfully processed.
-   Your information has to be erased for compliance with a legal obligation to which we are subject.

If you want to exercise oneof theserights please contact us at contact@profinpartners.com

If you believe that any information we are holding on you is incorrect or incomplete, please email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.

How long we keep your information

We will keep your information only as long as necessary to fulfil the purposes for which it was collected and processed. This includes legal, regulatory, accounting, or reporting requirements.

Changes to this notice

We may change this policy from time to time. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 25th May 2018.

Further information

In the event you have a complaint, we can be of help and can endeavour to solve the issue at hand. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.

For any other information, please contact us on contact@profinpartners.com.