Privacy notice - articles

This Privacy Notice (Notice) explains how Patron Capital Advisers LLP (Patron Capital, 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.

Patron Capital 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).

Patron Capital is registered as a data controller with the UK Information Commissioner's Office under registration number Z2745781.

This Notice was updated on 25th May 2018 and supersedes any previous privacy notice or similar terms provided by, or on behalf of, Patron Capital.

If you have any questions about your rights or how your personal data is used by Patron Capital, you should contact the Data Protection Representative using the details below:

  • Post - Kendall Langford
    One Vine Street
    London
    W1J 0AH
  • Email - legal@patroncapital.com
  • Telephone - +44 (0)207 629 9417

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.patroncapital.com) (for example when you log into the Investor Portal). For further information see our Privacy and Cookie policy for the website which can be found at www.patroncapital.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 andtelephone number);
  • Information about your background including occupation, educational informationand interests.

The basis for processing your personal data, how that data is used and whom it is shared with

(i) 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:
    • Our advisers (such as lawyers or accountants) where it is necessary to obtain their advice or assistance;
    • Third parties who assist us with the services listed above (such as IT providers).

(ii) 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:
    • 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:
    • Our advisers (such as lawyers or accountants) where it is necessary toobtain their advice or assistance;
    • 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 - Kendall Langford
    One Vine Street
    London
    W1J 0AH
  • Email - legal@patroncapital.com
  • Telephone - +44 (0)207 629 9417

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 standardc ontractual 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 transferredoutside the EEA (including a copy of any standard contractual clauses which Patron Capitalhas entered into with recipients of your personal information) by contacting the Data ProtectionRepresentative 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 youcease to be interested in the articles that we share, unless that personal data is required to beretained 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 suchof your personal data as is necessary, and for such reasonable additional period, in order tomaintain that relationship.

Your rights

Prior to 25 May 2018, 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;

Once GDPR comes into force, from 25 May 2018 you will also have the following additionalrights:

  • 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).